CMS seeks comment on secondary interpretations

The Centers for Medicare & Medicaid Services (CMS) recently unveiled the 2015 Medicare Physician Fee Schedule (MPFS) proposed rule, which largely directed cuts at radiation therapy centers and radiation oncology rather than imaging.

A summary analysis of the proposed rule conducted by the American College of Radiology (ACR) listed the overall reimbursement impact on total allowed charges for radiation therapy centers to be a net loss of 8 percent, with a 4 percent drop for radiation oncology. The biggest impact came from CMS’ proposal to treat radiation treatment vaults as an indirect practice expense, rather than a direct practice expense, which would affect reimbursement for more than a dozen radiation treatment procedures.

The proposed MPFS’ overall reimbursement impact on radiology and interventional radiology was pegged at -2 percent and –1 percent, respectively, by the ACR, while nuclear medicine ticked up 1 percent.

Beyond the proposed cuts and changes asked for by CMS, one of the more interesting things about the proposed rule is the indication that CMS wants to closely examine payment for secondary interpretation of images. Here are a few of the questions on which CMS is seeking comment:

• For which radiology services are physicians currently conducting secondary interpretations, and what, if any, institutional policies are in place to determine when existing images are utilized? To what extent are physicians seeking payment for these secondary interpretations from Medicare or other payers?
• We believe most secondary interpretations would be likely to take place in the hospital setting. Are there other settings in which claims for secondary interpretations would be likely to reduce duplicative imaging services?
• How should the value of routine secondary interpretations be determined? Is it appropriate to apply a modifier to current codes or are new HCPCS codes for secondary interpretations necessary?

The bottom line is that CMS is investigating whether more routine payment of secondary interpretations would actually generate cost savings by cutting down on potentially unnecessary duplicative imaging. This seems likely, and even if payment for secondary interpretations is limited to certain advanced diagnostic imaging service, if it can reduce duplicative services it would not only save Medicare money, it would keep patients from having to undergo unneeded additional exams. We are interested in hearing what comments come from CMS’ questions.

We are also interested to hear you as our application period for the 2014 Patient-Centric Imaging Awards winds down. If your practice or one you know well has recently undertaken a quality improvement project that is getting results, tell us about it!

-Evan Godt
Editor – Health Imaging