Warning that proposed new cuts in Medicare reimbursement could afflict U.S. healthcare with “severe and permanent damage,” the Radiology Business Management Association has presented CMS with detailed recommendations for stopping such a dire scenario from arising.
RBMA states its case in a letter it sent the agency Sept. 6, the deadline for commenting on CMS’s proposed Medicare physician fee schedule (MPFS) for 2023.
Addressed to CMS administrator Chiquita Brooks-LaSure and signed by RBMA executive director Robert Still, the nine-page communiqué urges CMS to bear in mind that any fee reduction it lays down will “resonate across the medical practice ecosystem.”
This will surely occur, RBMA notes, since private health insurers and other payers use Medicare rates to calculate and negotiate their own.
Pointing to the annual rituality of the exercise, RBMA encourages CMS to “work along with the committees of jurisdiction in Congress to seek a solution to this multiple-year trend of payment cuts” to healthcare providers—not least radiologists.
Lingering COVID, Continuing Inflation, Rising Interest Rates
RBMA projects that, under the approaching arrangement comprising the 2023 PFS and related plans, radiologists would have to live with a total reduction in pay of 12.0%.
It bases this figure on the combined effect of four looming cuts—3.0% to the Medicare Conversion Factor, 3.0% to radiology RVUs, 4.0% in pay-as-you-go (PAYGO) reductions and 2% Medicare sequestration intended to align CMS’s budget with overall federal budget goals.
RBMA tells CMS a compensation drop of this magnitude is “unsustainable in the current environment.”
The organization describes several factors that will hit U.S. healthcare with particular force in 2023.
These include lingering pressures from the COVID pandemic, current and likely continuing 8.5% to 9% inflation, and rising health insurance premiums for support staff as well as physicians and other clinicians.
Meanwhile radiology, dependent as it is on costly capital equipment, is likely to be stung in 2023 by rising interest rates. These, coupled with price hikes owing to supply chain disruptions, RBMA writes,
... affect the ability of radiology practices to invest in life-saving imaging equipment and ever-improving advancements in radiology information systems, picture archival communications systems and other technologies required under various state and federal regulations (i.e., interconnectivity with the rest of the healthcare delivery system to serve patients).”
Practice Managers Brace for Hard Times Ahead
RBMA also relays to CMS results of a survey of its 50-state, 2,200-strong membership conducted in August.
Asking about expected effects of the 2023 PFS, RBMA found 63% of 62 responding radiology practice managers anticipate reducing operational overhead by pruning benefits, outsourcing services and/or downsizing staff.
In addition, some 58% expect to restructure physician compensation, 23% may take fewer Medicare patients and 34% are considering shortened hours of operation.
Maybe most tellingly, the RBMA member survey found more than 80% of radiology practices have contracts with private payers that base their rates on the Medicare PFS.
RBMA further found 61% of its sample group troubled by a “significant shortage” of radiologists. These practice managers indicated the proposed 2023 PFS cuts would slash their wherewithal for recruiting and retaining radiologists. In the process, the reductions would shrink patient access and balloon patient wait times, the organization explains.
‘The Practice of Radiology Has Changed Dramatically’
Turning to measures of direct and indirect costs used to calculate practice expense RVUs in the PFS, RBMA cites CMS’s own expressed concern over the formulas behind the figures as well as the age of some data.
Here RBMA states it “strongly supports revisiting” the Physician Practice Information (PPI) survey and asks CMS for a chance to collaborate in any updating effort along these lines.
More:
Today, no current data exists to accurately represent the indirect costs of radiology. The previous survey conducted in 2007 used the American Medical Association’s physician master file to identify who should receive the survey instrument—and ultimately did not include sufficient responses to provide accurate information. … [T]he practice of radiology has changed dramatically since that survey, as the structure of radiology entities has become increasingly complex.”
RBMA closes its comment letter on the proposed 2023 Medicare PFS by imploring CMS to stand up and speak out “on behalf of the entire Medicare population and all the providers” who serve them.
“We urge CMS to publicly reach out to key Congressional committee leaders and engage in discussions with them to provide appropriate funding and support efforts for long-term and stable healthcare delivery solutions,” the organization concludes. “RBMA will be ready to provide support in the form of data and real-life examples.”
Dave P. has worked in journalism, marketing and public relations for more than 30 years, frequently concentrating on hospitals, healthcare technology and Catholic communications. He has also specialized in fundraising communications, ghostwriting for CEOs of local, national and global charities, nonprofits and foundations.