Comment period nears end to avert sharp payment cuts for nuc cardiology

The 2010 proposed rule for Medicare payments in the physician fee schedule released by the Centers for Medicare & Medicaid Services (CMS) in July poses serious threats to nuclear cardiology practices and the patients they serve, according to the American Society of Nuclear Cardiology (ASNC). The comment period about the proposed CMS changes closes Aug. 31.

The proposed rule affects physician, office and independent diagnostic testing facility (IDTF) payments for services paid under the resource based relative value scale (RBRVS), also known as the Medicare Physician Fee Schedule (MPFS).

Proposed policies related to nuclear cardiology include:

• Conversion Factor: Unless legislation addressing the physician payment update is passed by Congress and signed into law by President Barack Obama, the conversion factor for 2010 will be $28.3208—21.5 percent less than the conversion factor in effect for 2009. The 21.5 percent physician payment cut would be in addition to all other payment reductions proposed by CMS for 2010.

• Practice Expense Value: CMS is proposing to incorporate the results of the American Medical Association's (AMA) Physician Practice Information (PPI) survey into its formula for calculating practice expense RVUs. Results from the PPI survey showed sharp declines for cardiology, particularly equipment-based services. If fully implemented, nuclear cardiology payments would decrease between 10 and 30 percent per service based on the survey results. SPECT myocardial perfusion imaging would receive approximately a 28 percent cut due to full implementation of the survey.

• Equipment Utilization: CMS is proposing to change the equipment usage assumption from the current 50 percent usage rate to a 90 percent usage rate for equipment priced over $1 million based on MedPAC's recommendation in its March report to Congress. CMS stated that it will continue to explore data sources regarding the utilization rates of equipment priced at less than $1 million, but is not proposing a change in the usage rate for this less expensive equipment at this time.

• Malpractice RVUs: CMS proposed to update the malpractice RVUs with data from a new survey of specialty-level malpractice premiums. In addition, CMS has proposed a new method for determining malpractice RVUs for technical component services. The proposed new malpractice RVUs would reduce cardiology payments by 1 percent.

• Accreditation: Consistent with the accreditation provision in the Medicare Improvement for Patients and Providers Act (MIPPA), the proposed rule sets forth criteria for designating organizations to accredit suppliers furnishing the technical component (TC) of advanced diagnostic imaging services and sets forth the required procedures to ensure that the criteria used by an accreditation organization meet minimum standards for each imaging modality. Under the accreditation requirement in MIPPA, beginning Jan. 1, 2012, Medicare payments may only be made for the TC of advanced diagnostic imaging services (including nuclear cardiology) to a supplier who is accredited by an accreditation organization designated by the Secretary of Health and Human Services (HHS).

• Quality Incentives: The proposed rule includes modification of criteria for reporting e-prescribing measures, as well as modifications and additions to the Physician Quality Reporting Initiative (PQRI) for 2010. Physicians or group practices that meet the requirements of e-prescribing and PQRI in 2010 will be eligible for incentive payments for each program equal to 2 percent of their total estimated allowed charges for the reporting periods.

“It is imperative that CMS and Congress hear from cardiologists on how the implementation of such damaging policies will genuinely affect your ability to practice medicine and care for patients in the most effective manner,” ASNC said.

The 2010 MPFS proposed rule is posted on the CMS Web site.