Controversial reporting requirement—opposed by Rad Partners, Rayus, ACR and RBMA—set to take effect
A controversial Centers for Medicare & Medicaid Services reporting requirement, opposed by radiology societies and providers, is set to take effect soon, imaging leaders warned Thursday.
On Oct. 1, CMS will begin enforcing use of the JW or JZ modifiers for claims tied to drugs in single-use vials or packages, paid for separately under Medicare Part B. The American College of Radiology, Radiology Business Management Association, Rayus and Rad Partners challenged this change over the summer, believing it to be too burdensome for physician groups to maintain.
“These requirements add a significant amount of additional time, resource, and administrative costs to providers, with no additional benefit to CMS,” the four organizations wrote in a letter to the agency in July.
The Infrastructure Investment and Jobs Act mandates that manufacturers provide a refund to CMS for any unused portions of drugs that come in single-use packaging. However, the rule does not pertain to radiopharmaceuticals or imaging agents, the four organizations emphasized in their letter. The 2023 Medicare Physician Fee Schedule advises that providers should use one of two modifiers to clarify such scenarios—JW for discarded drug amounts or JZ to attest that there weren’t any leftovers.
Given the volume of studies affected by the change, ACR et al. previously said they are dismayed by the enormity of the undertaking. Each year, providers serve Medicare patients with more than 3 million enhanced imaging studies and 1.5 million diagnostic nuclear medicine exams involving radiopharmaceuticals. Performing exams under the new mandate would call for updated workflows and forms, among other changes. What’s more, the agents in question are often delivered on-demand in premeasured doses, leaving nothing to report
ACR posted a news update to its members on Sept. 21, urging radiology providers to be ready for the update. It emphasized that the mandate does, in fact, pertain to radiopharmaceuticals and contrast agents used in medical imaging.
“Also beginning Oct. 1, claims for drugs from single-dose containers that do not appropriately use the JW/JZ modifiers will be returned as un-processable until claims are properly submitted,” the college noted.
All four organizations met with CMS to ask the agency to waive the reporting requirement ahead of next month’s go-live date, according to the update.
Marty Stempniak has covered healthcare since 2012, with his byline appearing in the American Hospital Association's member magazine, Modern Healthcare and McKnight's. Prior to that, he wrote about village government and local business for his hometown newspaper in Oak Park, Illinois. He won a Peter Lisagor and Gold EXCEL awards in 2017 for his coverage of the opioid epidemic.