Radiologists urge CMS to quash proposal that would slash pay for 2nd services delivered in same visit

Radiology societies are urging the Centers for Medicare & Medicaid Services to quash a proposal that would slash provider pay when a second service is delivered during a single visit. 

Outlined in the physician fee schedule, CMS is proposing to pay 50% of full price in certain scenarios where patients visit an office and receive a second service the same day. The feds are advancing the proposal on the assumption that treatments are “likely” duplicated in these scenarios, with no evidence to back this claim, docs contend. 

Over 150 medical groups including nearly every state medical society wrote to CMS Administrator Mehmet C. Oz, MD, MBA, Thursday to voice their opposition to the proposal. Those signing the message included the American College of Radiology, American Society of Neuroradiology, Society of Interventional Radiology, the American College of Radiation Oncology and the American Medical Association.

They note that CMS killed a “substantially similar” proposal in 2019 and is failing to address the same shortcomings seven years later. 

“We appreciate the Trump administration’s emphasis on keeping independent physician practices sustainable, yet we believe the unintended consequence of CMS’ proposed policy will make it extremely difficult for those practices to remain viable,” the medical societies wrote Aug. 27. 

Radiologists are asking the agency not to finalize the proposed 50% payment reduction for services furnished on the same date (as a separately identifiable office/outpatient evaluation and management visit reported with modifier -25). They also are asking CMS not to extend the policy to procedures furnished on the same date as inpatient or other E/M services. Physicians want the agency to instead address any “genuine overlap” in services through the established misvalued code and AMA/Specialty Society RVS Update Committee (RUC) valuation process. They’re hoping CMS will do so on a code-specific basis, rather than through a uniform, payment-level reduction. 

“A payment reduction of this scope, applied across thousands of codes and every affected specialty, should rest on demonstrated duplication in identified services, not an assumption,” radiologists and other physicians charge. “CMS has not quantified the overlap it asserts, identified the specific resources it believes are duplicated, or shown that current payment systematically overstates the work and practice expense required to furnish these services.”

Experts note that the new proposal is broader than the failed 2019 version. This time, it extends to 10- and 90-day global procedures and reduces all same-day services other than the highest value one. Docs contend that an agency reviving and expanding a policy it previously declined to finalize should, “at a minimum, explain the basis for its changed position.” 

A broad, 50% reduction to second services in single visits lacks precision, the writers charge. And doing so would disproportionately impact independent, office-based practices. These doc groups bear the full cost of clinical staff, supplies and equipment reflected in the nonfacility payment and cannot offset the reduction with facility revenue. For some common procedures, the reduced payment would fall below the direct cost of furnishing the service, they charge. 

“A policy that pays below the cost of providing care runs counter to CMS’ stated goal of sustaining independent practice and risks accelerating the consolidation CMS has identified as a concern,” radiologists charge. “We urge CMS to withdraw the proposal and to work with physicians and other healthcare professionals to address any demonstrated instances of duplicative payment through targeted, evidence-based means,” they added later. 

Others signing the message included the American College of Surgeons, American Nurses Association, Medical Group Management Association, the American Society of Nuclear Cardiology and the Society for Cardiovascular Angiography and Interventions.