How to prepare for CMS proposed cuts to mammography reimbursements

CMS will likely propose a 50 percent cut to the technical component of mammography reimbursement in the 2018 Medicare Physician Fee Schedule (MPFS) proposed rule, due to be released in early July. Slashing mammography reimbursement could drive down access to mammography, according to industry experts, so imaging organizations are raising questions about outdated reimbursement formulas in an attempt to prevent the cuts.

The Relative Value Scale Update Committee recommended halving the technical component relative value units (RVUs) for mammography studies in the 2017 proposed MPFS rule, but it was removed in the final rule—CMS cited a need for further review. However, industry experts expect the reduction to make it into at least the proposed rule for 2018.

If the reduction survives the comment stage, it could drive down access to mammography especially at small providers, according to Bob Still, executive director of the Radiology Business Management Association (RBMA).

“They may pull back some of their site offerings for mammography and this could have a detrimental impact on mammography services,” he said. “I think providers are going to be faced with those kinds of issues.”

The proposed cuts may even head off investment, spooking practices who are thinking of adding an imaging center or upgrading equipment. Fortunately, RBMA and other imaging advocates are on the case.

“We’re aligned with other industry organizations and we’ve worked closely with the American College of Radiology,” Still said. “for a number of years we’ve been submitting data to CMS because reimbursements are driven by formulas—this formula we believe is using old data.”

In fact, CMS may be relying on data from 2008, a lifetime ago in the fast-moving world of imaging technology. Only nine percent of non-federal hospitals had fully implemented electronic medical records (EMR) in 2008, according to a brief from the Office of the National Coordinator for Health Information Technology. Today, almost 97 percent of hospitals have adopted certified EMR, at an average outlay between $15,000 and $75,000 per care provider.  

Other contributors to increased overhead include breast density notifications and image storage requirements, according to Still.

“Some of the information technology costs related to image storage may not be up to date in those formulas—You don’t have to go too far to look at all of the new costs we have today,” he said. “That's what our effort is, to make sure CMS has the most up to date data, so the formulas will produce the correct reimbursements.”

However, with the 2018 MPFS proposed rule just over the horizon, radiologists may be best served by turning the looking glass inwards. 

“I would use this time to go back to my administrators and review both direct and indirect costs and expenses related to mammography programs,” he added. “If this proposed rule is issued, we’re going to need those kinds of numbers to drive the point home that the data is out of date.”

The 2018 MPFS proposed rule is expected to be issued in early July and the final rule is usually issued around the beginning of November.