Proposed 2017 MPFS is a mixed bag for radiology

When the U.S. Centers for Medicare and Medicaid Services (CMS) releases its proposed Medicare Physician Fee Schedule (MPFS) each year, the news isn't always good. For 2017, the proposed rule is a typical mishmash, containing some provisions that benefit radiology and some that don't.

What's the quick-and-dirty version? Payment rates will decrease by 1% for radiology overall, but interventional radiology will see cuts of 7%. The requirement to use clinical decision support based on appropriate use criteria will begin in January 2018, rather than 2017, a move CMS announced this year and reinforces in this proposed rule. New mammography codes will bundle the exam with computer-aided detection (CAD) when the two are performed together -- and payments will not be reduced as a result. And CMS has added a proposal that prices professional PACS workstations at $14,617, which will improve payments across more than 400 current procedural terminology (CPT) codes.

"As usual, this proposed rule is a mixed bag," Katie Keysor, director of economics and health policy at the American College of Radiology (ACR), told AuntMinnie.com. "But there are several provisions we're pleased to see that will benefit radiology."

Payment percentages

CMS estimates a 2017 conversion factor of $35.75, which reflects the 0.5% update dictated by the Medicare Access and CHIP Reauthorization Act, a budget neutrality adjustment, and a 5% adjustment due to the multiple procedure payment reduction (MPPR) for the professional component of imaging services. The new conversion factor is slightly decreased from the current factor of $35.80.

What does this mean for radiology? CMS estimates that overall payments will decrease by 1%. Nuclear medicine and radiation oncology payment rates will remain the same, but interventional radiologists will see steeper cuts, with an aggregate decrease of 7%.

The MPPR percentage decrease is good news, according to the ACR. In 2015, Congress passed the Consolidated Appropriations Act of 2016, which included a provision that CMS lower the existing 25% professional component MPPR to 5%, effective 2017; this provision is finally going into effect, the ACR said.

Clinical decision support

The Protecting Access to Medicare Act of 2014 (PAMA) directed CMS to develop an appropriate use criteria/clinical decision-support (AUC/CDS) program for advanced diagnostic imaging services -- that is, diagnostic MR, CT, and nuclear medicine (including PET). This program was mandated to be implemented in January 2017, but last year the agency announced that this would be delayed. The new proposed rule suggests an implementation date of January 1, 2018, the ACR said.

"We felt that a January 2017 implementation was possible, but CMS wanted to use a rule-making process to develop the program and give clinicians time to prepare," Keysor said. "We're just glad the proposed implementation date isn't beyond 2018."

CMS is also suggesting specific requirements for how CDS/AUC is reported, using a clinical decision-support mechanism (CDSM). This electronic tool built by companies such as National Decision Support Company -- which developed ACR Select -- will communicate appropriate use criteria information to clinicians and help them make appropriate treatment decisions, CMS said.

CMS plans to take applications from CDSM developers from the publication date of its final MPFS 2017 rule until January 1, 2017; qualified CDSMs will be announced by June 30 of next year.

Mammography and CAD

Three new mammography codes will be implemented in 2017 that bundle mammography with computer-aided detection when it is used, the ACR said. These codes will be structured similarly to the existing mammography codes, with a code for unilateral diagnostic mammography, a code for bilateral diagnostic mammography, and a code for screening mammography. These new codes will replace the current codes used to report mammography (77055-77057) and CAD (77051 and 77052).

The good news? Bundling often means a decrease in reimbursement, but for this rule CMS is proposing to increase the physician work RVUs for diagnostic mammography and maintain the current value for screening mammography, the ACR said.

PACS pricing

In this proposed rule, CMS is carrying forward the 2016 MPFS rule's pricing for the technical component of PACS workstations at $5,557. It also plans to price the professional component of PACS workstations at $14,617, the ACR said. This latter change will be applied to 426 radiology CPT codes.

"Before last year's MPFS, CMS had valued the technical PACS workstation as it would a desktop computer," Keysor said. "It remedied this in 2016, and in this proposed rule it's keeping that pricing of almost $5,500. In addition, CMS hasn't previously included professional PACS workstation pricing in its CPT code calculations, so adding a professional PACS workstation component of almost $15,000 is good news."

RVU reductions

Finally, CMS is proposing a clarification in the implementation of a provision set by PAMA to phase in RVU reductions of 20% or more over a two-year period. In last year's rule, CMS proposed and finalized that any RVU reduction over 20% will be reduced by 19% in the first year and the remaining reduction in the second. In this rule, CMS proposes a clarification that the maximum decrease in each year will be 19%. For codes faced with higher reductions, up to 50%, the cut would be limited to a decrease of 19% each year until the total reduction is reached -- meaning the phase-in period could be longer than two years, CMS said.

"This phase-in idea was intended to be a 'dampening' policy," Keysor said. "It may help for those codes with big cuts, but not so much for those with cuts of 20%."

More analysis to come

The ACR plans to conduct a detailed analysis of the proposed rule in the coming weeks. In the meantime, the document will be published in the Federal Register on July 15. CMS is accepting comments on it until September 6.