Medicare proposes a 50% cut for some imaging fees in 2012

Rates would be reduced for interpreting multiple advanced imaging scans performed on a patient during the same visit.

By Charles Fiegl — Posted July 18, 2011

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As physicians try to stop an across-the-board Medicare pay cut of 29.5% from taking effect in January, the Centers for Medicare & Medicaid Services is proposing additional pay reductions for certain specialists and penalties for those who fail to prescribe electronically next year.

The proposed 2012 physician fee schedule released July 1 paints a gloomy picture for doctors participating in Medicare. CMS is required by statute to implement the across-the-board cut unless Congress steps in to prevent it. But the agency also would expand its multiple procedure payment reduction policy to physicians who interpret the results of certain advanced diagnostic imaging scans.

CMS already reduces what it pays for the technical component of the procedures when multiple scans are provided to the same patient on the same day. Now the agency is proposing to extend the reduction to the professional component, which would affect rates for the doctors interpreting the images. So a physician who interprets more than one MRI or CT scan taken of the same patient during the same visit, for instance, would see a 50% reduction in pay for interpreting the second and any subsequent scans.

The proposal extends a multiple procedure policy that already has been applied to certain surgical and therapy services, and CMS might not stop there. The agency has said that money that is saved by reducing rates for overvalued services helps boost pay for primary care and other services that it considers undervalued.

The latest imaging cut proposal prompted a strong reaction from radiologists. Many CMS pay revisions are first approved by Congress or recommended by a rate review panel convened by the AMA, but not in this case.

"This is a bold attempt by CMS to reduce physician payments without specific authorizing legislation, and to usurp the function of the AMA Relative Value Update Committee without any supporting evidence," said John A. Patti, MD, chair of the American College of Radiology Board of Chancellors. "If this proposal is allowed to stand, eventually all physicians will be affected, and physicians will not be properly compensated for the work they do."

There are a number of examples of how the pay reductions would go too far, including complex cases where the patient is badly injured, Dr. Patti said. For instance, a physician would receive less pay for doing the same amount of work when interpreting separate CT scans of the head, neck, chest, abdomen and pelvis of a trauma patient.

"There is published evidence to support a payment reduction of 3% to 5%, but there is no evidence to support a reduction of 50%," he said.

Not every specialty that provides imaging services would be affected equally. The services that CMS plans to cut, for instance, are not commonly provided by cardiologists, said Brian Whitman, associate director of regulatory affairs for the American College of Cardiology. However, cardiologists are concerned that the agency will expand the policy to all diagnostic imaging, he said.

CMS does warn in the proposed fee schedule that physicians interpreting multiple x-rays and ultrasounds for the same patient visit may receive reduced payments, possibly starting in 2013. Diagnostic services offered by certain specialties, such as cardiology, also could see payment reductions when the technical component of a test is billed at the same time as another service.

The CMS proposal on imaging mirrors some of the advice of the Medicare Payment Advisory Commission. The AMA has disagreed with that approach and suggested the policy would compromise care.

The AMA is reviewing the 621-page proposed fee schedule, said AMA President Peter W. Carmel, MD. But statutory payment policy outlined in the rule shows Congress must act to fix a flawed pay system, he said.

"Many physicians are already struggling with inadequate Medicare payment rates and the ongoing threat of future cuts from the broken Medicare physician payment system," Dr. Carmel said.

The Association has recommended that CMS use its regulatory authority to review and revise the Medicare Economic Index used to calculate physician practice expenses. Revisions to the MEI could reduce the cost to Congress of a permanent replacement to the Medicare payment formula, Dr. Carmel said.

In the proposed fee schedule, CMS said it would apply a similar approach used this year to implement Medicare electronic prescribing penalties in future years, meaning doctors must e-prescribe in 2012 to avoid a 1.5% penalty in 2013.

An eligible professional would need to report at least 10 e-prescribing transactions during the first six months of next year to avoid the penalty. However, CMS would allow physicians to report e-prescribing activity during any patient encounter in 2012. Current program policy limits eligible e-prescribing encounters to certain services, such as office visits.

Physicians who earn bonuses for e-prescribing this year would not be subject to the 2013 penalty. Doctors who earn bonuses for e-prescribing in 2012 also would not be penalized in 2014, when the pay cut rises to 2%.

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How specialties would fare

The impact of cuts on imaging pay -- and other Medicare payment policy changes that CMS is proposing to implement or phase in for 2012 -- varies depending on the specialty. These percentages would be reduced further if a scheduled 29.5% across-the-board cut takes effect before Congress steps in.

Specialty Projected 2012 spending (in millions) Change
Allergy/immunology $194 1%
Anesthesiology $1,847 2%
Cardiac surgery $384 -1%
Cardiology $6,778 -1%
Colon and rectal surgery $146 1%
Critical care $252 0%
Dermatology $2,931 0%
Emergency medicine $2,658 -1%
Endocrinology $415 0%
Family practice $5,640 1%
Gastroenterology $1,837 0%
General practice $656 1%
General surgery $2,277 0%
Geriatrics $200 1%
Hand surgery $121 1%
Hematology/oncology $1,912 0%
Infectious disease $597 0%
Internal medicine $10,737 1%
Interventional pain management $448 1%
Interventional radiology $211 -2%
Multispecialty clinic/other $84 0%
Nephrology $2,011 0%
Neurology $1,520 2%
Neurosurgery $669 0%
Nuclear medicine $53 -3%
Obstetrics-gynecology $678 0%
Ophthalmology $5,316 2%
Orthopedic surgery $3,572 1%
Otolaryngology $1,001 1%
Pathology $1,122 -1%
Pediatrics $68 1%
Physical medicine $928 2%
Plastic surgery $339 0%
Psychiatry $1,134 0%
Pulmonary disease $1,758 0%
Radiation oncology $1,968 -4%
Radiology $4,722 -4%
Rheumatology $530 0%
Thoracic surgery $371 -1%
Urology $1,919 -2%
Vascular surgery $749 -1%

Source: Centers for Medicare & Medicaid Services (link)

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What a 30% cut would look like

The sustainable growth rate formula will lower pay for Medicare services by about 30% in 2012 unless Congress prevents the reduction. CMS provided several examples of what effect this would have on individual services.

Service 2011 payment 2012 payment Change
New office visit $102.95 $73.57 -$29.38
Established office visit $68.97 $49.13 -$19.84
Chest x-ray $23.78 $16.53 -$7.25
Mammogram $110.76 $77.64 -$33.12
Intracoronary stent insertion $873.19 $588.30 -$284.89
Total knee arthroplasty $1,539.47 $1,081.71 -$457.76

Source: Centers for Medicare & Medicaid Services (link)

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External links

Proposed 2012 Medicare physician fee schedule, Centers for Medicare & Medicaid Services, July (link)

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