Radiology Coding Alert

CMS backed away from a 50 percent pro fee cut, but did the agency back away far enough?

Coders know that as the weather gets cooler, the wait to see what will happen with the Medicare conversion factor begins.

For 2011, Congress voted to stave off a 25 percent cut to your Medicare pay. However, that vote only keeps the cuts at bay through Dec. 31, 2011 -- and that date is right around the corner. Effective January 1, your Medicare pay is set to drop again based on the new 2012 Fee Schedule information, unless Congress intervenes to reverse the cuts.

"The calendar year 2012 Physician Fee Schedule conversion factor is $24.6712," notes the 2012 Medicare Physician Fee Schedule Final Rule (with comment period).

This amounts to a dismal 27.4 percent cut compared to the current rate of $33.9764. Physician advocacy organizations were quick to decry the cuts. Even CMS officials agreed that the 27.4 percent cut would be devastating, but remained hopeful that the government might rectify the situation before the pay cuts kick in. "This payment rate cut would have dire consequences that should not be allowed to happen," said CMS administrator Donald Berwick, MD, in a Nov. 1 statement. "We need a permanent SGR [sustainable growth rate] fix to solve this problem once and for all."

MPPR Could Slash Pro Fee in 2012

Even if Congress votes to hold the conversion factor steady, another major issue faces radiology practices. The 2012 Final Rule expands the existing multiple procedure payment reduction (MPPR) policy from the technical component to the professional interpretation of advanced imaging services. Currently, when you perform multiple radiological procedures, you collect 100 percent of the global fee for your primary study. For the second and subsequent studies (when MPPR applies), however, you collect 100 percent of the professional component and only 50 percent of the technical component.

CMS announced that in 2012, it will not only continue to slash the technical component of subsequent radiological procedures by 50 percent, but will also begin to cut the professional component by 25 percent. This is better than the 50 percent professional component cut that CMS had proposed, but still higher than radiologists would like to see.

Unpopular addition: CMS plans to apply the MPPR pro fee cut to multiple providers within the same group practice. "This extension of the multiple procedure payment reduction to include physicians in the same group practice was not specifically included in the 2012 Medicare Fee Schedule Proposed Rule. No efficiencies in care support a funding cut when different physicians in a group practice interpret separate imaging scans for the same patient. There is no scientific support for this action. The Centers for Medicare and Medicaid Services should rescind it immediately," said John A. Patti, MD, chair of the American College of Radiology Board of Chancellors.     

The complete Fee Schedule (with comment period) will be posted in the Nov. 28 Federal Register, but it is online ahead of print for a limited time at http://ofr.gov/OFRUpload/OFRData/2011-28597_PI.pdf.