The Medical Imaging & Technology Alliance (MITA) today sent two comment letters to the Centers for Medicare & Medicaid Services (CMS) outlining its position on the proposed Physician Fee Schedule (PFS) rule, as well as the proposed Hospital Outpatient Prospective Payment System (HOPPS) rule for 2021.
“It is our goal, in both of these letters, to provide evidence-based feedback and key policy recommendations that will ensure greater stability– and predictability– in the healthcare delivery system amid the unprecedented circumstances imposed by the COVID-19 pandemic,” said Patrick Hope, Executive Director of MITA.
In its comment letter addressing the HOPPS proposed rule for 2021, MITA provided several recommendations to increase patient access to advanced diagnostic procedures and ensure more equitable reimbursement for various imaging services furnished in the hospital outpatient setting.
For example, MITA comments criticized the current Medicare policy of bundling diagnostic radiopharmaceuticals and contrast agents as “supplies” in the hospital outpatient setting. The letter asserts that the current bundling policy for diagnostic imaging drugs discourages innovation and negatively impacts patient access to care and pressed CMS to treat these products as “drugs,” rather than “supplies.” The letter also recommends that CMS pay for diagnostic imaging drugs separately– a position that was recently reinforced by the Advisory Panel on Hospital Outpatient Payment.
Given inaccuracies and inconsistencies in current cost-reporting practices, MITA also recommended that CMS develop a more effective methodology that accurately captures hospitals’ costs for furnishing items and services. As the letter notes, “current cost-reporting practices do not accurately reflect the true cost of delivering imaging services. Cost-reporting now is administratively burdensome and overly complicated, meaning that some costs are not reported accurately by some providers.”
To improve the cost-reporting regime, MITA urged CMS to continue working with interested parties on “detailed instructions to hospitals that address the appropriate reporting of nonstandard cost center codes. This would improve the accuracy of the cost center data used to calculate CT and MRI CCRs applicable to the payment rates calculated under HOPPS.”
Other recommendations in the HOPPS letter requested policy updates to ensure appropriate payment for SPECT Imaging, cardiac CT services, and prostate high-intensity focused ultrasound.
For the proposed PFS rule, the MITA comment letter outlined a series of urgently necessary recommendations, including the need to delay implementation of forthcoming changes to evaluation and management (E&M) payments. This will have a profoundly negative impact on specialty physicians, including radiologists and other healthcare professionals.
In the absence of Congressional action to waive budget neutrality provisions for the proposed E&M changes, MITA suggested that CMS should at a minimum: (1) delay the implementation of the policy changes until a future date, (2) phase-in implementation of the policy changes, or (3) delay or cancel the implementation of the GPC1X add-on code.
“These deep cuts, which would undermine patient access to diagnostic imaging procedures during a public health emergency, are ill-advised and potentially dangerous,” said Hope. “We strongly urge CMS to reverse course and protect this well-proven pillar of America’s healthcare infrastructure.”
In the PFS comment letter, MITA also pressed CMS to recognize how the pandemic will affect future rate setting for various healthcare services. As the document notes: “It is becoming clear that the COVID-19 pandemic has resulted in significant changes to utilization patterns for healthcare services, including imaging. CMS should take steps to ensure that its rate-setting methodologies reflect the new realities of care.”
Specifically, MITA urged CMS to study the impact of the costs associated with increased infection control protocols on the practice expense assumptions for a wide variety of services, including medical imaging exams, physician office visits, and surgical procedures, among others.
To read the MITA comment letter on the proposed HOPPS rule for CY 2021, click here.
To read the MITA comment letter on the proposed PFS rule for CY 2021, click here.