More Than Theoretical
ACR’s impact on payment policy goes beyond intangible goals and makes a measurable difference for radiologists and their patients.
After an eventful legislative finale for 2015, I’ve been pondering the impact on radiology of the Consolidated Appropriations Act of 2016 (also called the Omnibus Reconciliation Act) enacted by Congress in December 2015. Our influence resulted in the inclusion of the roll back of the professional component Multiple Procedure Payment Reduction policy (MPPR) from 25 percent to 5 percent.
While the College has certainly been forward thinking in preparing our specialty and membership for the transition from volume to value and new payment models, we have also worked very hard to protect radiology’s position within the Medicare Physician Fee Schedule.
While one objective of the ACR Strategic Plan is to “increase ACR’s leadership role in defining, developing, evaluating, and advocating for new payment models that promote high value, patient-centered radiological care,” the first objective in the Healthcare and Payment Policies and Practice Models section of the Strategic Plan is to “ensure radiology’s relative value under the existing fee-for-service model and minimize further payment cuts.” I’m frequently reminded by members that, while preparing for the future is important, fee-for-service is here and now. At times it seems radiology is still in the crosshairs for payment cuts. Many of you have heard or read the ACR strategy around the volume-to-value initiatives and alternate payment models, and some may believe that’s all we have been doing. But, in fact, there is so much more.
The College’s work in the Medicare Physician Fee Schedule system began with development of the Resource-Based Relative Value Scale in the late 1980s. This radiology-specific relative value scale is now integrated into the Medicare Resource-Based Relative Value Scale. Looking back, this was perhaps the sentinel event in defining the College’s role in economics and advocacy.
Since 1992, the ACR has been a vital contributor to the CPT editorial panel and the AMA Specialty Society Relative Value Update Committee (RUC). We all recognize that the dramatic growth in imaging that occurred between 2000 and 2007 resulted in significant reimbursement cuts primarily to the technical component payment of imaging services. Even though we were not completely successful, we worked diligently with CMS, Congress, and the RUC to mitigate these cuts. At the same time, the zeal of policymakers to find resources to fund increases in payment for primary care services made reimbursement cuts to our professional work (called the professional component, or PC) a threat as well. Despite the threat, there have only been minimal reductions to our PC work, mostly through bundling of payments for services such as CT abdomen and pelvis. The credit for this goes to our ACR volunteers and staff in the Commission on Economics who have spent time in the trenches of coding and reimbursement to ensure our payment remains on par with other physician specialties.
Despite what I would say has been a generally successful two and a half decades of maintaining radiology’s place in the fee-for-service system, one aspect of professional component payment reductions has seemed particularly egregious to me. That is the MPPR instituted by CMS in 2012. At that time, CMS implemented a policy to reduce the payments for advanced imaging procedures by 50 percent when performed on the same day in the same session as another advanced imaging study. After outcry from the ACR and other specialty societies, the reduction was cut to a slightly better 25 percent.
We all know that the work of interpreting multiple procedures is not significantly reduced just because there is more than one examination, so we repeatedly asked CMS for the data justifying the policy. At the same time, we analyzed the Medicare data used by CMS and found that the efficiencies CMS initially placed at 50 percent were no more than 5 percent. When CMS would not respond to our requests for information around its analysis, we took our case to Congress and received widespread bipartisan support for changing the policy to better reflect our data. The Consolidated Appropriations Act finally afforded our key Congressional supporters, including Congressman Fred Upton (R-MI) and Sen. Orrin Hatch (R-UT), an opportunity to mitigate the PC MPPR. The legislation reduced the PC MPPR from 25 percent to 5 percent to be in line with the data previously published by the ACR Commission on Economics. The rollback will take effect Jan. 1, 2017.
The College’s ability to make this payment policy change a reality should allay any fears that we are too focused on theoretical alternate payment models or value initiatives. While it is easy for CMS and Congress to implement payment policy changes with the stroke of a pen, it is rare that specialty societies are able to roll back these policies. Mitigating the effects of the PC MPPR has been a priority since 2012, and it is wonderful to see the hard work of our government relations team and the volunteers and staff of the Commission on Economics make such a difference on behalf of our specialty.
I’ve always been proud of the College’s ability to focus on the main thing. Our success was clearly the result of all the work that goes into maintaining our relationships with key members of Congress, such as Congressman Upton, Sen. Hatch, and many others. In addition to our personal relationships, over the past three years, RADPAC has also supported the campaigns of these key members of Congress with individual contributions and through more significant independent expenditures. These independent expenditures help us keep radiology’s allies in Congress.
Additionally, the omnibus appropriations package also included legislative language delaying any coverage changes for screening mammography based on the recommendations of the U.S. Preventive Services Task Force for two years. This will ensure access to care for our patients who elect to follow the ACR recommendations for screening mammography. The ACR believes its support of annual screening mammography for women beginning at age 40 saves thousands of lives that otherwise might be lost if the task force’s recommendations for less frequent screening are adopted. Another major legislative victory took place earlier in 2015 with the repeal of the Sustainable Growth Rate (SGR) formula as the means to calculate Medicare payments. This occurred through the enactment of the April 2015 Medicare Access and Chip Reauthorization Act, which the ACR strongly supported. The legislation replaced the flawed SGR formula with updates generally tied to a new Merit-Based Incentive Payment System (MIPS) for Medicare and incentives for a transition to alternate payment models.
So while some might argue that the move from volume to value and emerging alternate payment models remain theoretical, seeing these transitions in legislative language makes me believe they will soon be reality. However, I am not concerned. I believe our Imaging 3.0 initiatives have prepared us well. We have the tools in place that will allow us to adapt and thrive in the future. If you’re ready to take the next step to prepare for the future of health care, enroll in the R-SCAN program at rscan.org. We are ready for our next marathon.
By Bibb Allen Jr., MD, FACR, Chair