Radiology Coding Alert

Learn about the AUC program’s fate in the MPFS proposed rule.

The Centers for Medicare & Medicaid Services (CMS) issued its calendar year (CY) 2024 Medicare Physician Fee Schedule (MPFS) proposed rule on July 13, 2023. Coming in at nearly 2,000 pages, the MPFS delivers disappointing reimbursement news for radiology practices.

Get up to speed on the proposed changes to the MPFS with this detailed summary.

Learn Which Specialties Are Hurt by the Proposed CF Changes

CMS is proposing a conversion factor (CF) of $32.75 for 2024, which is a $1.14 reduction when compared to the $33.89 2023 CF — or a 3.34 percent decrease. Many providers were hoping that CMS would leave the CF alone for 2024 since providers are still fighting inflation and financially recovering from the COVID-19 public health emergency (PHE).

“CMS is also proposing significant increases in payment for primary care and other kinds of direct patient care,” the agency wrote in a fact sheet. While those areas may see financial boosts, radiology practices are once again facing payment reductions if the proposals are finalized.

Without accounting for the Consolidated Appropriations Act (CAA) payment supplements for 2023 and 2024, the CMS estimates the reduced CF effects on the following radiology specialties:

• Radiology: 3 percent decrease
• Interventional radiology: 4 percent decrease
• Nuclear medicine: 3 percent decrease
• Radiation oncology: 2 percent decrease
• Radiation therapy centers: 2 percent decrease

The CAA payment supplements for 2023 and 2024 are 2.5 percent and 1.25 percent, respectively. These supplements are “statutory changes that take place outside of the budget neutrality adjustments. As such, the estimated specialty impact mentioned above will be approximately one to two percent higher,” the American College of Radiology (ACR) wrote in their 2024 MPFS proposed rule summary (www.acr.org/ Advocacy-and-Economics/Advocacy-News/Advocacy-News-Issues/In-the-July-29- 2023-Issue/ACR-Provides-Detailed-Summary-of-2024-Medicare-Physician-Fee- Schedule-Proposed-Rule).

Reactions to the MPFS Cuts

Physician payments, especially for radiology specialties, have been trending downward for years, and the healthcare industry isn’t pleased with the latest news. “When adjusted for inflation, Medicare physician payment already has effectively declined 26 percent from 2001 to 2023 before additional inflation and these cuts are factored in. Physicians are one of the only providers without an automatic inflationary increase,” says Jesse M. Ehrenfeld, MD, MPH, president of the American Medical Association (AMA).

Dr. Ehrenfeld continues to argue “this is almost biblical in its impact. Seven lean years that include a pandemic and rampaging inflation. Physicians need relief from this unsustainable journey.”

Radiology societies are urging Congress to take action to ensure providers receive fair reimbursement for their services. “Congress will be the ultimate decider in the final outcome of cuts radiologists face in 2024, underscoring the need for congressional action to permanently fix the Medicare physician payment system. The ACR will continue to work with Congress to build a permanent payment system that provides adequate provider reimbursement and guarantees Medicare beneficiaries have access to quality care,” said Cindy Moran, executive vice president, ACR Government Relations/Economics in a statement.

Radiologists administering therapy to patients, such as radiation oncologists, also face an uphill battle to receive reimbursement while also delivering proper care to patients. “Another year brings another round of cuts to radiation therapy services for people with cancer under the proposed Medicare fee schedule. ASTRO is disappointed that CMS once again undervalues the impact of radiation oncology and intends to cut reimbursement by an additional 2 percent in 2024 for this essential cornerstone of cancer care,” explained Geraldine M. Jacobson, MD, MBA, MPH, FASTRO, chair of the board of directors for the American Society for Radiation Oncology (ASTRO).

“The ongoing cuts to radiation oncology reimbursement, coupled with broader cuts to Medicare services, threaten to decrease patients’ ability to receive vital, high-value cancer care close to home by driving practice consolidation and undermining the viability of smaller practices,” Dr. Jacobsen adds.

Watch the AUC Program’s Sunset

In the CY 2024 MPFS, CMS is proposing an indefinite pause of the Appropriate Use Criteria (AUC) program. According to CMS, “we have exhausted all reasonable options for fully operationalizing the AUC program consistent with the statutory provisions as prescribed … As a result, we propose to pause implementation of the AUC program for reevaluation, and rescind the current AUC program regulations from § 414.94.”