On July 13, the U.S. Centers for Medicare and Medicaid Services (CMS) released a proposed rule for the 2018 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System that includes some positive changes for radiology -- the most important being a delay in changing how CT and MRI costs are calculated.
The proposed rule adds one level to the imaging ambulatory payment classification (APC) families, delays changes to how CT and MR costs are calculated, and adds two modifiers for use on claims for plain film and computed radiography (CR) exams, according to an American College of Radiology (ACR) analysis. All changes would be effective January 1, 2018.
Overall, CMS is proposing a 1.75% increase to the OPPS conversion factor, which brings it up to $76.48. The reduced conversion factor for hospitals failing to meet the Hospital Outpatient Quality Reporting (OQR) Program requirements would be $74.95.
Calculating MR, CT costs
CMS had planned to complete a change in how CT and MR cost data were calculated in 2018, using cost information from all providers, regardless of how it was determined (direct, dollar, or square-foot methods). The ACR expressed concerns about the square-foot cost allocation method, as it would cause reductions in imaging APC rates. In this proposed rule, CMS would extend the transition for an additional year and not use claims that include the square-foot cost calculation method, the ACR said.
"This would provide added flexibility for hospitals to improve their cost allocation methods during 2018," the ACR said. "Beginning in 2019, CMS will estimate the imaging APC relative payment weights using cost data from all providers, regardless of the cost allocation statistic employed."
The rule also proposes a slight decrease in payment for low-dose CT (LDCT) for lung cancer screening (code G0297), from $59.84 to $59.17. It will also decrease payment for visits to determine lung LDCT eligibility from $70.23 to $68.92.
Adding an APC
In addition, CMS is proposing a fifth level to its APCs for imaging: imaging without contrast. This additional level would come from splitting the level 4 imaging APC; the proposed level 4 imaging without contrast APC would include higher-volume, lower-cost services, while the proposed level 5 imaging without contrast APC would include low-frequency services with higher costs, the ACR said.
CMS is not proposing any new comprehensive APCs (C-APCs) in this rule, the ACR said. The rule does confirm that the agency will continue making separate payments for 10 planning and preparation services for stereotactic radiosurgery using cobalt-60 or linear accelerator-based technology.
X-ray modifiers
In the 2017 OPPS, CMS established a modifier, "FX," for film-screen x-rays and reduced payment for services under this modifier by 20%. This will continue in 2018. CMS also plans to establish a new "XX" modifier for CR exams, under which payments will be reduced by 7% between 2018 and 2022 and by 10% in 2023 and beyond.
