RBMA, ACR, RadNet and Rayus Radiology urge CMS to fix ‘burdensome’ reporting requirement

Two professional associations representing radiology business interests and two outpatient imaging providers are asking the Centers for Medicare & Medicaid Services to fix what they say is an overly burdensome reporting requirement.

ACR, the Radiology Business Management Association, RadNet Inc. and Rayus voiced their concerns in a July 18 letter to CMS’ Hospital & Ambulatory Policy Group. They want the federal agency to waive the modifier reporting obligation in Medicare Part B tied to separately payable imaging contrast agents and radiopharmaceuticals.

“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 to Laura Kennedy, PharmD, a health insurance specialist in the Division of Ambulatory Services.

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 radiopharmaceutical or imaging agents, the four organizations emphasized. The 2023 Medicare Physician Fee Schedule further outlined that providers should use one of two modifiers to clarify such scenarios—“JW” for discarded amounts or “JZ” to attest that there weren’t any leftovers.

Given the volume of studies affected by the change, ACR et al. are dismayed by the enormity of the undertaking. Each year, providers serve Medicare patients with more than 3 million enhanced imaging studies and more than 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.

“We are concerned that the JZ modifier may result in billing errors, inadvertent claim denials, and slow claims processing, not only for providers but also for CMS,” the groups wrote. “In particular, coordination of care with Medicare supplement plans and Medicare as a secondary payer could be problematic as these payers are slower to adopt new modifiers.”

ACR, RBMA, RadNet and Rayus are asking CMS to waive the requirement for these drugs. They’re also urging the agency to pause the July 1 launch and Oct. 1 claims denial dates as these issues are sorted.

You can read the full letter on RBMA’s website (membership sign-in required).