By Sheila M. Sferrella, CRA, FAHRA
Similar to the Hospital Outpatient Prospective Payment System (HOPPS), CMS also issues proposed rules for the Medicare Physician Fee Schedule (MPFS). These rules apply to physician offices and/or imaging centers that are paid for services through the submission of a CMS1500 claim form. There were multiple issues included in the proposed rules, but AHRA chose to focus on those issues that most affect our members.
AHRA submitted comments for the MPFS proposed rules on the following issues:
- NEMA Standard XR-29
- Low-Dose CT Lung Cancer Screening Billing Requirements
- Appropriate Use Criteria (AUC) for Advanced Diagnostic Imaging Services
- Phase-in of Significant Relative Value Unit (RVU) Reductions
- Practice Expense Inputs for Digital Imaging Services
- Definition of Eligible Professional (EP) for Participation in PQRS
- Equipment Maintenance
In our continuing effort to partner with other associations, AHRA worked once again with the American College of Radiology (ACR) and the Radiology Business Management Association (RBMA) to draft our response letter. We used the same language that was submitted in the OPPS response letter for the first two issues. The remaining issues were identified and addressed through feedback from AHRA members and the Regulatory Affairs Committee.
For the Appropriate Use Criteria issue, AHRA worked with the ACR to support the CMS’s definition of provider-led entities. AHRA also stated that the industry would need 12 to 18 months to comply with the regulations once CMS issues clear definitions and established mechanisms. AHRA is also a member of the e-Ordering Coalition working on the IHE implementation side of Clinical Decision Support.
While issues 4-7 all apply to the practice expense portion of Medicare reimbursement they are key issues that impact designated areas of the radiology industry.
We now wait for CMS’ response in the Final Rule which will be published November 2015.
Read a copy of both the AHRA comment letter to CMS and the CT Compliance Survey that many of you completed.
If you have any questions, please contact me. Thanks.
Sheila M. Sferrella, CRA, FAHRA is senior vice president, Regents Health Resources, Franklin, TN and chair of the AHRA Regulatory Affairs Committee. She can be contacted at email@example.com.