The U.S. Centers for Medicare and Medicaid Services (CMS) has released its final rule for the 2018 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System -- and there's both good and bad news for radiology.
One piece of (sort of) good news is that the rule delays full implementation of the agency's transitional CT and MR cost center policy until January 1, 2019, to offer hospitals additional time to improve their cost allocation methods next year.
The American College of Radiology (ACR) had raised concerns regarding using claims from all providers to calculate CT and MRI cost-to-charge ratios (CCRs) because many providers continue to use the square-feet cost allocation method, and future use of these claims would cause significant reductions in imaging ambulatory payment classification (APC) payment rates. CMS elected to delay the policy, but the ACR plans to continue to lobby that the policy be eliminated.
"We're still concerned about this policy and will be meeting with CMS next year to discuss why they want to continue pursuing it," Pamela Kassing, the ACR's senior economics and health policy advisor, told AuntMinnie.com. "CMS says that this new policy will increase our payments, but we think it will severely cut them -- to the tune of 25% for CTs and 15% for MRIs."
Odds and ends
Overall, the rule increases the OPPS conversion factor by 1.75%, bringing it up to $76.48 for 2018. The reduced conversion factor for hospitals failing to meet the Hospital Outpatient Quality Reporting (OQR) Program requirements will be $74.95.
The rule also sets a final payment rate for low-dose CT (LDCT) for lung cancer screening (code G0297) at $62.11, up from the rate of $59.17 proposed in July and an increase over 2017's $59.84. CMS also decided to forgo its proposed plan to decrease payment for visits to determine lung LDCT eligibility from $70.23 to $68.92, instead finalizing a payment rate of $71.94.
In addition, CMS has solidified its intention not to implement any new comprehensive APCs (C-APCs) for 2018. Instead, the agency will continue making separate payments for 10 planning and preparation services for stereotactic radiosurgery using cobalt-60 or linear accelerator-based technology.
Bad news?
As for bad news: The final rule adds two modifiers for use on claims for computed radiography (CR) exams, which will reduce payments for these services by 7% between 2018 and 2021; in subsequent years, this payment will be reduced a further 10%, the ACR said. The reductions are mandated by a law passed in 2016 to move healthcare providers to digital imaging.
Also, in this final rule, CMS has chosen not to add a fifth imaging-without-contrast APC. The additional APC would have come from splitting the previous level 4 imaging APC to create a new one that would include higher-volume, lower-cost services, and a level 5 imaging-without-contrast APC that would include low-frequency services with higher costs, the ACR said. In this final rule, CMS said that keeping the level 4 imaging-without-contrast APC intact will minimize fluctuations in payments rates and lead to payment stability going forward into 2018.
The ACR doesn't agree. In fact, not adding a fifth imaging-without-contrast APC will have a dramatic effect on some imaging payments, Kassing said: For example, CT of the abdomen and pelvis without contrast, followed by with contrast (code 74178) will be cut by 41%, while MRI of the bone marrow (code 77084) will be cut by 45%.
"It's not clear to us why CMS doesn't look more thoroughly into the impact of their decisions," she told AuntMinnie.com. "These cuts are actually better than the ones floated in the proposed rule, but without adding this additional fifth-level APC, some of these higher-level imaging study payments aren't as stable as they should be."
