Medicare fee schedule proposes pay cut for diagnostic and interventional radiology; ditching AUC program also on the table

CMS released the initial 2024 Medicare Physician Fee Schedule late Thursday, proposing a pay cut for diagnostic and interventional radiology. It additionally suggests possibly rescinding the long-delayed Appropriate Use Criteria Program, which is now on hold indefinitely.

The preliminary relative value unit changes include a -3% reduction for diagnostic radiology, -4% for interventional specialists, -3% for nuclear medicine and -2% for radiation oncology (ASTRO also criticized the proposal on Thursday). In addition, the proposed 2024 MPFS conversion factor, which is the dollar amount used to convert RVUs into payment, is $32.7476, representing a 3.36% reduction from the 2023 amount.

Imaging experts could not quote an exact figure for the total cuts across each specialty as of late Thursday, but expressed disappointment with the initial numbers.

“The chronic, 16-year, cycle of double-digit cuts to Medicare providers must come to an end. With nearly half of eligible American women not receiving their annual mammogram, it’s unconscionable that radiology is again on the chopping block,” Bob Still, executive director of the Radiology Business Management Association, told Radiology Business. “The data that CMS has relied upon is clearly flawed. We look forward to working with members of Congress to advance meaningful, long-term reform to protect Medicare beneficiaries and safety net programs.”

The Medical Group Management Association, which represents more than 15,000 physician groups across radiology and other specialties, said the 3.36% cut to the conversion factor “raises significant concerns.” Such a reduction would only further increase the growing gap between radiology practice expenses and reimbursement rates.

“Medicare already largely fails to cover the cost of furnishing care to beneficiaries, and the proposed cut to the 2024 conversion factor compounds the problem,” Anders Gilberg, MGMA’s senior VP of government affairs, said Thursday. “Congress must reexamine existing law to provide an annual physician payment update commensurate with inflation and do away with Medicare’s ‘robbing Peter to pay Paul’ budget neutrality requirements to provide much-needed financial stability for medical practices,” he added later.

Potential AUC repeal

CMS also is proposing to potentially do away with the long-delayed imaging Appropriate Use Criteria Program. First established in 2014, the initiative requires physicians to consult a decision-support system before ordering MR, CT and other advanced imaging to help curb healthcare waste. But it’s been plagued by postponements and other challenges. CMS acknowledged such in the proposed fee schedule.

“We believe the inherent risks in terms of data integrity and accuracy, beneficiary access, and potential beneficiary financial liability for advanced diagnostic imaging services render the AUC program impracticable, and have led us to our proposal to pause efforts to implement the AUC program for reevaluation and rescind current regulations," the rule notes.

CMS has not identified any “practical way” to move beyond the educational and operations-testing period. Officials said they would continue to explore a “workable implementation approach” and may seek to adopt such a refresh through future rule-making.

“MGMA shared these concerns, so we are relieved that CMS is not moving forward with a program they cannot properly implement,” Claire Ernst, director of government affairs for the Englewood, Colorado-based association, told Radiology Business.

RBMA, meanwhile, noted that there are “numerous” other examples of decision support delivering cost savings and clinical improvements by making sure patients receive the right imaging exam at the right time.

“CDS isn’t going away with this proposal, but it will continue to evolve,” RBMA President Christopher “Kit” Crancer told Radiology Business. “We’ve already seen Congress express the need for independently derived, real-time decision-making in the Medicare Advantage space, and we continually hear of the technology’s expansion into the commercial market.”

CMS acknowledged the value of clinical decision support in helping to “improve the quality, safety and efficiency and effectiveness of healthcare.” The agency also is encouraging continued volunteer use of such tools, the American College of Radiology noted Thursday.

“The ACR recognizes the significant issues CMS faces with the real-time claims processing aspect of the AUC program and the potential impact on our members should claims be denied inappropriately,” ACR said Thursday. “The college is working with Congress to streamline and modernize the [Protecting Access to Medicare Act] AUC program, including the removal of this requirement, to allow the program to move forward and ensure Medicare patients receive the right imaging tests at the right time.”

The Centers for Medicare & Medicaid Services is accepting comments on the proposed rule through Sept. 11. 

For further information about the fee schedule, you can read initial analyses from ACR and the American Hospital Association, the press release from CMS, a related fact sheet, and the 1,920-page rule itself.

Editor’s Note: An earlier version of this story erroneously included a 4% PAYGO (Pay as You Go) cut as part of the proposed reductions. However, the Consolidated Appropriations Act, 2023, waived this provision through the entirety of 2024. Radiology Business regrets this error. ACR also issued a statement on the inaccuracy and later estimated the cut to diagnostic radiology at 4%.