In what has seemingly become an annual event, the U.S. Centers for Medicare and Medicaid Services (CMS) has once again included radiology reimbursement cuts in its Medicare Physician Fee Schedule (MPFS) Proposed Rule.
Notably, the July 13 announcement also included a proposal to pause the Appropriate Use Criteria (AUC) program for the ordering of advanced diagnostic imaging services.
CMS estimated a $32.7476 conversion factor for 2024, down from the $33.8872 conversion factor in 2023. Radiology would be hit with an estimated 3% decrease in reimbursement while interventional radiology would see a 4% aggregate decrease and nuclear medicine would have a 3% decrease. Meanwhile, radiation oncology and radiation therapy centers would experience an estimated 2% decrease.
"Part of the decrease is due to changes in relative value units (RVUs) and the third year of the transition to clinical labor pricing updates," the American College of Radiology (ACR) said in its preliminary analysis of the proposed rule.
CMS is also proposing to pause the Protecting Access to Medicare Act (PAMA) AUC program for reevaluation. The current educational and testing period would be ended.
The real-time claims processing aspect of the statute "presents an insurmountable barrier to CMS to fully operationalize the AUC program," CMS said. No timeline was proposed for resuming implementation of the program.
"The ACR recognizes the significant issues CMS faces with the real time claims processing aspect of the AUC program and the potential impact on our members should claims be denied inappropriately," the ACR wrote. "The College is working with Congress to streamline and modernize the PAMA AUC program, including the removal of this requirement, to allow the program to move forward and ensure Medicare patients receive the right imaging tests at the right time."
The ACR also noted that CMS acknowledges the value of clinical decision support (CDS) to "improve the quality, safety and efficiency and effectiveness of health care" and encourages the continued voluntary use of CDS tools.
"The College continues to review the proposed rule and will provide a detailed summary in the coming days," the ACR said.
A number of other radiology-specific provisions were included in the proposed rule. For example, CMS has accepted the American Medical Association/Specialty Society Relative Value Scale Update Committee-recommended values for the radiology codes pertaining to ultrasound guidance for vascular access, the dorsal sacroiliac joint, and fractional flow reserve.
"The ACR will continue to review the proposed rule, including the practice expense refinements to the neuromuscular ultrasound codes," the college wrote.
The American Society for Radiation Oncology also weighed in, suggesting that the proposed rule could limit patient access to care.
"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," it said.
In the Quality Payment Program, CMS has proposed no quality scoring changes for 2024. However, it proposed removing three radiology-oriented measures, including:
- MIPS 147: Nuclear Medicine: Correlation with Existing Imaging Studies for All Patients Undergoing Bone Scintigraphy
- MIPS 324: Cardiac Stress Imaging Not Meeting Appropriate Use Criteria: Testing in Asymptomatic, Low-Risk Patients
- MIPS 436: Radiation Consideration for Adult CT: Utilization of Dose Lowering Techniques
A new measure would also be added to the Diagnostic Radiology measure set:
- #TBD: Excessive Radiation Dose or Inadequate Image Quality for Diagnostic Computed Tomography (CT) in Adults
The 2024 MPFS Proposed Rule can be found here and the ACR's radiology-specific preliminary summary can be found here.
