American College of Radiology concerned with CMS proposal to slash $260M in imaging spending
The American College of Radiology is expressing concern over a Medicare proposal to slash some $260 million in imaging spending, worried it could have “unintended consequences for beneficiary access.”
Outlined in July as part of the 2027 Hospital Outpatient Prospective Payment System proposed rule, CMS is seeking to reduce spending on radiology services using site-neutral reforms. It would do so by paying for hospital outpatient care using the lower rate used in the physician fee schedule.
The agency said its goal is to curb unnecessary increases in the volume of clinic visit services furnished at certain off-campus hospital departments. Federal authorities want to move more care to physician offices, where it can be delivered cheaply, after previously doing so for certain drug-administration services.
However, in recently submitted comments, the college charged that CMS has failed to prove payment differences between hospital outpatient departments and doc offices are the primary driver of imaging utilization growth. Nor has the agency established that the imaging services targeted represent “unnecessary volume warranting intervention.”
“Before implementing a non-budget neutral payment reduction for selected imaging services, CMS should provide stronger evidence demonstrating that payment policy … is responsible for the utilization trends the agency seeks to address,” ACR CEO Dana Smetherman, MD, MBA, MPH, recently wrote to the agency.
Rather, the college believes other factors could be fueling increased imaging utilization at hospital outpatient departments. These could include evolving patient needs, demographic trends, expanding clinical indications, improved access to diagnostic services, or shifts in care delivery patterns, Smetherman wrote.
More broadly, ACR is concerned that the proposal selectively targets certain ambulatory payment classifications and cost centers without considering the framework underlying the outpatient payment schedule. The system is built on claims-based average costs and designed to reflect the resources required to furnish services in hospitals, ACR charged.
“By using a separate payment methodology to reduce reimbursement for selected [ambulatory payment classifications] based on concerns about utilization rather than resource consumption, CMS risks undermining the integrity of the APC structure and creating payment policies that are increasingly disconnected from the cost-based principles on which the OPPS was established,” Smetherman wrote.
The college also expressed concern that several preventive imaging services—such as CT colonography, lung cancer screenings and DXA scans—are targeted by the proposal. Applying the physician fee schedule rate to these services could have unintended consequences for beneficiary access to screenings, ACR believes. For example, reducing payment could affect provider capacity and availability, creating barriers to access that could discourage patient adherence to cancer screening regimens.
“CMS should carefully evaluate the impact of this proposal on preventive imaging services and consider whether additional safeguards are necessary to ensure continued access to these important imaging screening examinations,” Smetherman charged.
You can read the full comments, submitted to CMS Administrator Mehmet Oz, MD, here. ACR also touched on several other subjects in the OPPS, including diagnostic radiopharmaceutical payment policy, the 340B remedy offset and Hospital Outpatient Quality Reporting Program updates. The college promoted its concerns in a news update, published on Sept. 2.
CMS is expected to release the final hospital outpatient payment rule in November. The American Hospital Association also has voiced opposition to such site-neutral reforms.
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.