MPFS: CMS proposes CPT codes that would address MRI patient safety

The U.S. Centers for Medicare and Medicaid Services (CMS) in its suggested 2025 Medicare Physician Fee Schedule (MPFS) has proposed new CPT codes that would address additional labor involved in imaging patients who have contraindications for MRI.

These tasks can include looking up the patient’s medical record or the specifics of implants/devices, performing risk/benefit analyses for patients with complications, planning risk-mitigating steps for MRI exams for patients with complications, and preparing MRI-specific programming for MR conditional active devices (such as pacemakers) before and after exams, according to Tobias Gilk, founder of Gilk Radiology Consultants in Overland Park, KS, and senior vice president of Radiology-Planning in Mission, KS.

"If approved, these CPT codes would be the first time that CMS reimbursement would accommodate the additional time/energy/effort that patients with implants or foreign bodies can require to clear for MRI exams," he told AuntMinnie.com. "Up until now, MRI providers that accept more complicated patients were essentially uncompensated for the additional complexity of safely managing those patients."

The codes include the following and can be found on page 152 of the proposed MPFS rule (descriptions from CMS):

  • CPT code 7XX00. (MR safety implant and/or foreign body assessment by trained clinical staff, including identification and verification of implant components from appropriate sources, analyzing current MR conditional status of individual components and systems, and consulting published professional guidance with written report; initial 15 minutes).
  • CPT code 7XX01. (MR safety implant and/or foreign body assessment by trained clinical staff, including identification and verification of implant components from appropriate sources, analyzing current MR conditional status of individual components and systems, and consulting published professional guidance with written report; each additional 30 minutes (List separately in addition to code for primary procedure).
  • CPT code 7XX02. (MR safety determination by a physician or other qualified health care professional responsible for the safety of the MR procedure, including review of implant MR conditions for indicated MR exam, analysis of risk versus clinical benefit of performing MR exam, and determination of MR equipment, accessory equipment, and expertise required to perform examination with written report).
  • CPT code 7XX03. (MR safety medical physics examination customization, planning and performance monitoring by medical physicist or MR safety expert, with review and analysis by physician or qualified health care professional to prioritize and select views and imaging sequences, to tailor MR acquisition specific to restrictive requirements or artifacts associated with MR conditional implants or to mitigate risk of nonconditional implants or foreign bodies with written report).
  • CPT code 7XX04. (MR safety implant electronics preparation under supervision of physician or other qualified health care professional, including MR-specific programming of pulse generator and/or transmitter to verify device integrity, protection of device internal circuitry from MR electromagnetic fields, and protection of patient from risks of unintended stimulation or heating while in the MR room with written report).
  • CPT code 7XX05. (MR safety implant positioning and/or immobilization under supervision of physician or qualified health care professional, including application of physical protections to secure implanted medical device from MR-induced translational or vibrational forces, magnetically induced functional changes, and/or prevention of radiofrequency burns from inadvertent tissue contact while in the MR room with written report).

"If [these changes go] through, [MRI providers] won't be at [a] disadvantage for accepting MRI patients with more safety complications," Gilk said.

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