As the Centers for Medicare & Medicaid Services, CMS, contemplates yet another pay cut to CT and MRI providers, the Radiology Business Management Association, RBMA, steps up to oppose them. Since 2006, there have been 12 radiology billing adjustments for imaging services with nine of those cuts directly affecting the technical component. Next year, the agency will provide new rules that affect radiology billing as part of the 2014 Medicare Hospital Outpatient Prospective Payment System, HOPPS and the 2014 Medicare Physician Fee Schedule, MPFS.
With the final ruling due November 1st of this year, RBMA sent comment letters to CNS expressing their concerns about the proposed payment programs and the changes to radiology billing protocols.
One key point that RBMA is bringing to the forefront is the planned implementation of new cost-to-charge ratios for computed tomography and magnetic resonance imaging. The system change will reduce payments going to radiology centers working in hospital outpatient departments by as much as 38 percent. According to RBMA, an abdomen CT without contrast will pay the same rate as a less complex two-view x-ray of the same area. RBMA points out in its letter of opposition that doing a CT scan costs the service provider much more than the basic x-ray.
RBMA offers a counter plan to CMS requesting they adopt minimum data quality standards for the new CCRs. They also ask the agency to delay implementation of the new system and allow for a full assessment of the impact of these payment cuts on radiology billing. They go on to suggest the organization further define the label “off-campus provider-based” before any attempt to collect information from these businesses or determining the payment they receive.
Deficit Reduction Act of 2005
RBMA brings up the effect the Deficit Reduction Act of 2005 has already had on radiology billing in their letters. Enactment of the new HOPPS rates will bring down the pay for CT and MRI services by an additional 12 to 35 percent. The DRA provides a cap for technical component payment for advanced imaging services to the lesser of the MPFS or HOPPS rate.
The association opposes capping non-facility practice expense for approximately 200 CPT codes found in radiology billing in addition to MRI, CT and ultrasound services. The new system expands Medicare’s multiple procedure payment reduction platform to include other types of imaging, as well.
A featured point in their letters to CMS discusses RBMA’s stand against pushing the 90 percent equipment usage rate assumption beyond the current standards to include additional imaging formats in radiology billing.
The Radiology Business Management Association has a good relationship with CMS, so the agency is confident their opposition will be a consideration. RBMA Federal Affairs Committee Chair, Barbara Rubel, suggests that the complaints about the expansion of MPPR and the cost-to-ratio processing will garner the most attention from the board.
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