AHRA responds to MPFS proposed rule

AHRA has submitted its response to the 2016 Medicare Physician Fee Schedule (MPFS) proposed rule, recommending a one-year delay before new XR-29 requirements are enforced and requesting additional information on clinical decision support (CDS) implementation.

The response, signed by AHRA CEO Edward J. Cronin, Jr., was written with assistance from both the American College of Radiology (ACR) and Radiology Business Management Association (RBMA).

In total, the response included seven specific points of contention, beginning with the association’s thoughts on the XR-29-2013 standard.

It’s already mandated that, beginning Jan. 1, 2016, Medicare will pay less for scans performed on CT systems found to not comply with the XR-29 standard. In its proposed rule, CMS broke down how this requirement would be tracked, identifying all affected billing codes and introducing a new modifier code to be used with all noncompliant equipment.

After studying the industry and receiving over 500 replies to its XR-29 readiness survey, AHRA recommended giving imaging departments an additional year to catch up with this new provision.

“Unfortunately, the timetable mandated by Congress is unreasonable,” the association wrote. “Although tremendous progress has been (and will continue to be) made on upgrading CT equipment, based upon our industry assessment, hundreds of hospitals will still have at least one piece of non-compliant CT equipment in service after the January 1 effective date.”

AHRA added that the standard technically only applies to Medicare patients, but it impacts the entire imaging department.

“CMS should understand that when a patient presents to the imaging department for a CT scan, the requisition or order for the radiology service does not always connote that the patient’s care is covered by Medicare, commercial insurance, Medicaid or no insurance,” the association wrote. “The technologists performing the scan does not usually know the type of insurance coverage a particular patient might have at that point in time.”

AHRA also asked CMS to clarify its expectations in regards to CDS implementation. Beginning on Jan. 1, 2017, physicians will be required to consult with appropriate use criteria before ordering certain exams, but the association wrote that there isn’t enough information yet for imaging departments to begin adapting.  

“Hospitals and imaging centers will not be able to prepare for this mandate until CMS clarifies exactly how they expect the data elements above to be communicated,” the association wrote. “If the specifics are released in the 2017 physician fee schedule and the mandate remains January 1, 2017, then it will be very difficult for the industry to be prepared.”

The AHRA also said imaging departments will have budgets to manage in the near future, and realistic budgets can’t be put together properly until more information about CDS implementation is made available.   

“Operating budgets are typically developed a year or more ahead of time and many hospitals and imaging centers may have difficulty properly budgeting for CDS software that is yet to be developed and priced,” the association wrote.

The AHRA response to the MPFS proposed rule also included:

• A request for clarification about low-dose CT lung cancer billing requirements;
• A request for consistency in regards to eligible professionals participating in the Physician Quality Reporting System; and
• A counter-proposal that would limit the first-year reduction of relative value units to 50 percent, not 19 percent.

CMS released the proposed rule back in July, noting it would accept comments until Sept. 8 and a final rule could be expected on or around Nov. 1. 

The full AHRA response can be found on the association’s website.