Radiology societies raise concern about Medicare Physician Fee Schedule: 4 takeaways
Radiology societies are raising concern about the proposed 2027 Medicare Physician Fee Schedule, asking the federal government to make changes and stave off harming already-vulnerable imaging groups.
First released July, CMS is suggesting a conversion factor—used to calculate provider payments—of $32.84, a 1.68% reduction from 2026. This results from the expiration of a one-time, 2.5% doc pay bump under the Working Families Tax Cut Act.
Imaging societies including the Radiology Business Management Association, Society of Interventional Radiology and others recently submitted their detailed feedback on the fee schedule. They’re asking CMS to reconsider any proposals that would reduce provider pay and further strain physician groups.
“RBMA would be remiss if we did not express our profound concern regarding the continued erosion of physician reimbursement under the Medicare program. For years, physician practices have been asked to do more with less,” association Co-Executive Director Linda Wilgus, MBA, and colleagues wrote to the agency on Sept. 10.
“While CMS and policymakers have increasingly looked to physicians to improve quality, advance value-based care, invest in technology, expand access, address workforce shortages, and reduce administrative burdens, Medicare payments have moved in the opposite direction,” RBMA added. “The result is a growing disconnect between the cost of delivering care and the reimbursement provided to support it.”
In its own comments, posted online Sept. 17, the Society of Interventional radiology highlighted four key issues of concern, echoed by other radiology groups. They include rad pay reductions, practice expense and site-of-service policies, modifier-25 payment cuts, and quality reporting requirements.
Here they are in further detail:
1. Physician pay reductions: Starting this year, CMS implemented a 2.5% “efficiency adjustment” to physician work RVUs (relative value units) for all non-time-based services. In 2027, the agency is planning to do so again while also applying this cut to another handful of newly established or revised codes, SIR notes.
Radiology groups are asking CMS to forgo this pay cut, which is predicated on providers becoming more efficient and handling services in a faster fashion. This despite radiologists facing increasing patient complexity and demands on doc services.
“ACR remains strongly opposed to the unilateral application of a 2.5% efficiency adjustment to all non-time-based procedures,” the American College of Radiology wrote in its comments, shared via a news update to its members on Sept. 17. “We reiterate our belief that any adjustment to a code’s time and value should be carefully considered and based on appropriate specialty-specific data. While there have been advancements in imaging technology, this does not necessarily translate into efficiency.”
For example, technological improvements may result in higher resolution or a greater number of images, ACR notes. This would, in turn, require more physician time for review and interpretation.
“We are concerned that these continued payment reductions will harm practices and limit patient access to care across all specialties,” ACR added, urging the agency to “pause this policy to thoroughly evaluate potential negative impacts.”
In its comments, the Society of Interventional Radiology charged that the proposed policy “undermines established relativity among services.” It does so by reducing the value of physician work, “irrespective of the actual clinical intensity, complexity or risk associated with a procedure.” SIR similarly urged CMS to quash the efficiency adjustment and come up with a more targeted alternative.
“Physician experience, technical skill, and clinical judgment should be recognized and appropriately valued, not presumed to decline solely because a service has become more familiar or technologically advanced,” SIR wrote Sept. 10.
2. Practice expense and site-of-service policies: For 2026, CMS finalized a policy to allocate half the amount of indirect practice-expense relative value units per work RVU for services furnished in the hospital facility setting, ACR notes. This compared to those allocated to services in other nonfacility, physician office settings.
ACR said it is concerned about the impact of this policy on physicians who staff hospitals but also have a private office and do their own scheduling. This is typical for many interventional radiologists, experts note. ACR and others are recommending that CMS pause implementation of this policy until the agency can establish a way to identify and exclude office-based docs who staff hospitals. This could potentially be done with a “G-code” to denote the difference.
In its own comments, the Radiology Business Management Association noted that IR is unusual among procedural specialties. That’s because a large share of what makes it valuable to patients happens where the system pays the least: inside the hospital, at nights and on weekends, for patients who didn’t schedule an appointment.
If CMS payment policies continue to reward office-based, scheduled IR procedures over hospital-based, on-call, emergency and inpatient situations, it may become harder for smaller hospitals to maintain IR coverage.
“We ask CMS to evaluate whether widening facility/nonfacility payment differentials could erode hospitals' ability to recruit and retain IR physicians capable of sustaining 24/7 trauma, stroke, PE and inpatient coverage…,” RBMA wrote.
SIR echoed these comments while also expressing concern about how Medicare plans to calculate and pay for indirect practice expenses. CMS has questioned the current methodology that relies on specialty survey data from the American Medical Association. It contends the existing approach is limited by old information, low survey response rates and a lack of objective cost info.
SIR said it appreciates efforts to improve these valuations. However, it’s concerned that new methods have “not been sufficiently validated.” It wants the agency to withdraw proposed changes to practice-expense calculations and work with medical societies on a better alternative.
“Any future reforms should be supported by robust empirical evidence, transparent methodology, and detailed service- and specialty-level impact analyses that enable stakeholders to independently assess the individual and cumulative effects of proposed changes before implementation,” SIR wrote.
The American Society of Neuroradiology also echoed these concerns in its own comments, submitted Sept. 4. ASNR similarly wants CMS to postpone practice-expense proposals until a future rule-making cycle. This would allow the feds to gather more granular, specialty-level data for each change, along with granting additional time to work with doc groups.
3. Modifier-25 payment cuts: Radiology societies also are expressing strong opposition to a proposal that would reduce payment for certain evaluation and management services. This would apply to care reported with modifier-25 when furnished on the same day as a procedure.
Imaging groups including ACR, ASNR, SIR and the American College of Radiation Oncology previously wrote to Medicare in August, voicing their concerns about the update. 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.
In its Sept. 10 comments, SIR noted that interventional radiologists often provide separately identifiable E/M services on the same day as procedures. This could include determining appropriateness, evaluating new symptoms or managing complications. The proposed policy would reduce payment for these E/M offerings, SIR noted, despite their distinct clinical purpose and medical necessity.
“SIR strongly opposes automatic payment reductions for appropriately reported E/M services billed with modifier-25,” the society wrote. “SIR is concerned that the proposal could discourage efficient, patient-centered care by creating financial incentives to separate evaluation and treatment into multiple visits, potentially increasing patient burden, delaying care, and adding administrative complexity,” it added later.
ACR suggested that appropriate coding and compliance could, instead, be addressed through continued education or medical review, rather than a “unilateral payment reduction on presumed duplication of work.” In comments posted online Sept. 11, the American Society of Radiation Oncology (ASTRO) asked CMS to provide more info on how the modifier-25 proposal, and other changes, would impact individual services.
“ASTRO invests substantial resources in analyzing Medicare payment data and evaluating the effects of proposed payment policies on radiation oncology services,” the society charged. “CMS should provide the data necessary to evaluate these proposals individually and in combination.”
4. Quality reporting requirements: And finally, radiology societies also voiced concern over proposed changes to CMS quality programs. This would include eliminating the traditional Merit-based Incentive Payment System (MIPS) and moving to new MIPS Value Pathways (or MVPs).
In a recent study, experts outlined how some of these changes could negatively impact diagnostic radiologists. In its comments, ACR said it appreciates efforts to make quality-reporting programs more clinically meaningful by developing these specialty-specific pathways. This is meant to better reflect the care that radiologists deliver, CMS believes.
However, ACR contends the proposed timeline to sunset traditional MIPs “heightens the importance” of ensuring that all radiology practices have meaningful and feasible MVP participation options before retiring MIPS.
“Radiology is highly subspecialized,” the college wrote. “Barriers remain when MVP measures do not align with clinicians’ scope of practice, cost measures are not attributable, or non-patient-facing clinicians lack control over interoperability requirements.”
SIR similarly charged that Medicare should not finalize a mandatory sunset of traditional MIPS until each specialty has sufficient, broadly applicable quality measures, improvement activities and cost metrics. The IR society is concerned that the transition away from MIPS may occur too quickly before enough measures are established for interventional specialists.
“ASTRO appreciates CMS’ continued efforts to improve the Merit-Based Incentive Payment System (MIPS),” the radiation oncology society added in its own comments. “However, we remain concerned about the agency’s goal of moving solely to MVPs given the lack of specialty-specific MVPs and the fact that meaningful alternatives exist, such as accreditation…”
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.