Radiology Coding Alert

Don't miss the proposal to expand the MPPR from technical to professional payment.

As if imaging practices didn't get enough bad news in 2011, CMS's payment proposals for 2012 indicate the situation could get even worse. Check out the proposed fee schedule changes, as well as news for MRI and Advance Beneficiary Notices (ABNs).

1. Focus on Potential Imaging Fee Cuts

On July 1, CMS released its proposed Medicare Physician Fee Schedule (MPFS) for 2012. The 621-page document, published in the July 19 Federal Register, offers a look into how the agency configures its relative value unit (RVU) assignments.

Imaging pay, hit hard over the last several years, will see further cuts if the proposed rule is finalized. Currently, when you perform multiple radiological procedures on the Multiple Procedure Payment Reduction (MPPR) list during a single session, Medicare reduces the technical component of the lower paid procedure(s) by 50 percent.

But CMS wants to further reduce those payments, noting in the proposal, "We continue to believe that there may be additional imaging and other diagnostic services for which there are efficiencies in work when furnished together."

The cuts: CMS is proposing that in 2012, it will not only slash the technical component of subsequent radiological procedures by 50 percent, but also will cut the professional component by 50 percent. "Full payment would be made for the PC [professional component] and TC [technical component] of the highest paid procedure, and payment would be reduced by 50 percent for the PC and TC for each additional procedure furnished to the same patient in the same session," the proposal notes. It also indicates that payment cuts to radiology procedures could be even deeper in 2013 and beyond.

Professional societies were quick to decry CMS's radiology cuts. "The AMA strongly opposes a proposal to use significant cuts to Medicare payments for diagnostic imaging to offset the cost of a trade agreement," said AMA President Peter W. Carmel, MD, in a June 29 statement. "Diagnostic imaging in particular has already seen significant reductions over the past five years, with payments for some services down over 60 percent and additional cuts scheduled to occur."

In addition, many radiologists noted that multiple interpretations of exams performed on one patient aren't less work-intensive than multiple interpretations of separate patients. "The time, intensity, and mental effort it takes to interpret an individual exam is relatively constant regardless of whether the patients' exams are interpreted separately or at the same session," said John A. Patti, MD, chair of the American College of Radiology Board of Chancellors in a July 4 statement. "Medicare should support such quality care and not repeatedly attempt to undermine it."

Coverage for MRI Update Is Official

In Radiology Coding Alert, vol. 13, no. 9, the Reader Question "Certain Pacemaker Patients May See MRI Coverage"  discussed CMS's proposed decision memo in favor of covering MRI scans for patients with MRI-safe pacemakers. Now that decision memo is official.

CMS "has determined that the evidence is adequate to conclude that magnetic resonance imaging (MRI) improves health outcomes for Medicare beneficiaries with implanted permanent pacemakers (PMs) when the PMs are used according to the FDAapprovedlabeling for use in an MRI environment," the decision memo states. Expect to see a change to section 220.2.C.1 of the National Coverage Determination Manual. You'll find the memo at www.cms.gov/medicare-coverage-database/details/ncadecision-memo.aspx?NCAId=252&fromdb=true.

Use New ABN by Nov. 1, CMS Says

It may seem like just yesterday that you switched over to the latest version of the ABN, but it's actually time again to upgrade to a newer version.

The latest version of the ABN form, CMS-R-193, with the release date of March 20, 2011, is now available at www.cms.gov/BNI by clicking the FFS Revised ABN link, said CMS's Donna Williamson during a June 28 CMS Open Door Forum. Although the form doesn't include any substantial changes, mandatory use of the new version begins on Nov. 1, 2011.

A caller to the forum asked why the form was updated in the absence of substantial changes because many practices find it cumbersome and expensive to switch over to new forms. CMS's Stewart Streimer replied that the current ABN form had an expiration date on it, and forms are customarily updated every three years based on provider comments.

Tip: For information on proper use of ABNs, see "Sidestep Common ABN Pitfalls With These Tips" on page 60.