Safeguarding Radiology

ACR members demonstrate the importance of radiology to the government and the public.safeguarding radiology

ACR members are up against significant challenges that cannot be resolved by the efforts of a single individual. But by working together and being engaged, the College moves legislative mountains and continues to fight organizations seeking to reduce Medicare reimbursements to radiologists.

To organize opposition to reimbursement cuts and future legislation that could negatively affect imaging, ACR leaders developed the Radiology Saves Lives (RSL) campaign in 2011. This initiative was designed to employ volunteers who would emphasize the fundamental importance of radiology through visits and correspondence with their national representatives as well as submissions to media outlets throughout the country.

Taking National Action

The genesis of the RSL campaign began in early 2011 when the Medicare Payment Advisory Commission (MedPAC) — a 17-member independent organization established to advise Congress on health-care issues — initially recommended that CMS place a multiple procedure payment reduction (MPPR) on the professional component (PC) of payments for advanced diagnostic imaging services. Such reductions "affect the most vulnerable of Medicare beneficiaries: people suffering from multiple traumas, stroke patients, and those with widespread cancer — all of whom often require multiple imaging scans to survive serious illness and injury, the interpretation of which can often require the expertise of several different radiologists," explained John A. Patti, MD, FACR, ACR president and former chair of the ACR Board of Chancellors, in a November 2011 press release (http://bit.ly/ACRPRNov32011).

In response to MedPAC's recommendation, the College submitted comments to CMS vehemently opposing the proposed measure. In its submission, the ACR also noted that MedPAC's recommendations lacked sufficient evidence regarding MPPR efficiencies to support its claims. To bring more weight to the cause, the ACR Commission on Economics submitted a paper in the JACR, which provided data refuting MedPAC's claim that MPPR reduced efficiencies when applied to the PC. The published article concluded that radiologists interpreting multiple images from the same patient on the same day equates to efficiencies of only 3 to 5 percent for the PC, depending on the modality. (See "Professional Component Payment Reductions for the Diagnostic Imaging Examinations When More Than One Service Is Rendered by the Same Provider in the Same Session: An Analysis of Relevant Payment Policy" JACR 8(9);2011:610-16.) In addition to the comments direct from ACR leaders, Reps. Pete Olson (R-Texas) and Jason Altmire (D-Penn.) spearheaded distribution of a letter (http://bit.ly/OlsonAltmireMPPR) to the House Ways and Means and Energy and Commerce committees regarding the MPPR recommendation. An excerpt is as follows:

"While we agree that more needs to be done to bring efficiencies to the Medicare program and slow the growth in health-care costs, we believe that applying a MPPR to the professional component of diagnostic imaging would not decrease utilization or increase efficiency given that reducing the professional component will primarily affect radiologists who, as consulting physicians, rarely order the imaging studies they are asked to interpret. Additionally, since each imaging service produces its own unique set of images that require individual interpretation, the radiologist is ethically and professionally obligated to expend the same amount of time and effort, regardless of whether the images were obtained on the same day or over multiple days."

However, the correspondence did not alter MedPAC's decision to recommend in the June 2011 Annual Report that Congress impose an MPPR to the PC of select advanced diagnostic imaging services. Following MedPAC's lead, in July 2011, the CMS released its 2012 Medicare Physician Fee Schedule proposed rule which included provisions applying a 50 percent MPPR on the PC of advanced diagnostic imaging services provided in a single session. To counter the CMS's proposition, the ACR Commission on Economics continued to voice its opposition by visiting with CMS staff in Baltimore.

In addition to the hard work of the commission, the ACR organized a grassroots e-mail campaign in which ACR members sent approximately 5,000 e-mails to the CMS voicing their disagreement with the proposed reduction. Meanwhile, congressional representatives, including Rep. Betty McCollum (D-Minn.), arranged for Donald M. Berwick, MD, then acting administrator of CMS, to visit two radiology facilities to witness first-hand the complexity involved in radiologists interpreting multiple images from the same patient, during the same session. When challenged during his visits, Berwick admitted that he could not identify many efficiencies within the PC.

Survey Says ...

The RSL campaign contributed to the efforts of members of Congress and the ACR leadership to oppose the potential reductions imposed on radiologists. It began with a national telephone survey designed to ask the public about their opinions toward imaging and its importance within the health-care delivery process. Approximately 1,000 American voters were polled between Aug. 31 and Sept. 6, 2011. Results showed the following:

• 70 percent oppose Medicare cuts to imaging services.
• More than 80 percent believe that diagnostic imaging is absolutely essential to proper diagnosis and treatment.
• 90 percent think imaging cuts will have an impact on early detection of medical conditions and diseases.
• 87 percent of women believe a mammogram will help them find a lump before it can be felt.

These data were featured in College ads placed in such publications as Politico and The Hill and were designed to promote the value of the specialty. ACR members who visited Congress also used the data to explain to their representatives the critical nature of imaging and the impact that a 50-percent PC MPPR could have on radiology. The ACR also released the poll's full report on the new RSL website www.radiologysaveslives.org.

Making an Impact

On Nov. 1, 2011, in response to intense, sustained opposition from the ACR and members of Congress, CMS finally declared that it would reduce the MPPR from 50 to 25 percent in its 2012 Medicare Fee Schedule Final Rule. Despite this success, however, the final rule also expanded the scope of the policy to include different physicians interpreting multiple images from the same patient, during the same session, on the same day.

From the moment that the final rule was released, the MPPR issue moved from a CMS regulatory issue to a strictly legislative battle. In response to the CMS-imposed reimbursement reduction, Representatives Olson and McCollum introduced the bipartisan Diagnostic Imaging Services Access Protection Act of 2011 (H.R. 3269). The legislation was designed to block the PC MPPR on imaging services in 2012, as well as outline a transparent, data-driven process for CMS to follow should it elect to impose an MPPR in 2013 and beyond. The bill was introduced with 32 original co-sponsors in October 2011, but as of press time had grown to 162 Republicans and 92 Democrats. In addition, in December 2011, CMS rescinded provisions to expand the MPPR policy to two different physicians interpreting multiple images from the same patient, during the same session, on the same day.

The ACR and its members continue to build support in favor of H.R. 3269. Due in part to the RSL grassroots efforts, in April 2012, Sens. Ben Cardin (D-Md.) and David Vitter (R-La.) co-sponsored a bill (S. 2347) that would rescind the 25-percent MPPR for the PC 60 days after the bill's enactment. In contrast to the House legislation, S. 2347 mandates that the Institute of Medicine, in conjunction with key medical specialty societies with expertise in diagnostic imaging, conduct a study prior to imposing a PC MPPR in 2013 and beyond.

Growing Grassroots

The bill's incredible number of co-sponsors is largely due to the determination and time spent by ACR members who visited staffers as well as members of Congress, held fundraisers, and welcomed representatives to their imaging facilities. Justin P. Smith, MD, from Inland Imaging Associates P.S., is Spokane, Wash., who provided readers with advocacy tips in "Turning Dollars Into Actions" on page 23 of the May 2012 Bulletin, explains that the RSL campaign acted as a great resource to educate congressional representatives as well as the public about how imaging works and how much radiologists care about their patients. "The idea of Radiology Saves Lives is that we want to take care of [patients] the best we can," says Smith. "That means that we will do our best to give our doctors the best information to help them help patients. Thanks to Radiology Saves Lives, it's very easy to convey that concept to members of Congress, patients, and the public."

The ultimate safety and health of patients is an easy concept for many individuals to understand and for radiologists like Kathleen A. Ryan, MD, from Eastern Radiological Associates in Billings, Mont., to express. Ryan penned a guest op-ed for Montana's Billings Gazette in which she wrote, "It's one thing to cut misspent funds from the Medicare budget. It's another thing altogether to tell an elderly patient that they can't have a scan that can potentially diagnose, and enable early treatment of, a life-threatening health condition. If Congress continues to cut funding for diagnostic imaging, these screenings and scans are going to be less accessible for Medicare-dependent seniors." (For more op-eds published in newspapers throughout the country, visit www.radiologysaveslives.org/media-center/news.)

ACR members such as Smith and Ryan continue to make a meaningful impact at the local and national level. As many significant legislative decisions are still undecided as of press time, with radiology hanging in the balance, ACR remains poised to call its members to action to promote and protect the value of radiology.


By Brett Hansen

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