On November 1, the U.S. Centers for Medicare and Medicaid Services (CMS) released its final rule for the 2018 Medicare Physician Fee Schedule (MPFS) -- and in an unusual twist, there are no cuts to radiology. CMS will also push back the date for starting clinical decision support (CDS) another year, to January 2020.
The rule brings good news to radiology in other ways as well: Expected cuts to independent diagnostic testing facilities (IDTFs) have been reduced from July's proposed rule, and mammography payments will remain stable, said Kathryn Keysor, the American College of Radiology's (ACR) director of economics and health policy.
"Honestly, from our initial analysis, this appears to be a great rule for radiology," Keysor told AuntMinnie.com.
Overall, the final rule includes a conversion factor of $35.99, up slightly from 2017's $35.89. The change reflects a 0.5% update required by the Medicare Access and CHIP Reauthorization Act (MACRA), a budget neutrality adjustment, and a 0.09% target recapture adjustment, CMS said.
Delay is ... OK?
In the rule, CMS also announced that implementation of clinical decision-support reporting based on appropriate use criteria (AUC) will now begin in January 2020.
"The program will begin in a manner that allows practitioners more time to focus on and adjust to the Quality Payment Program before being required to participate in the AUC program," CMS said. "The ... program will begin with an educational and operations testing year in 2020. During this first year, CMS is proposing to pay claims for advanced diagnostic imaging services regardless of whether they correctly contain information on the required AUC consultation. This allows both clinicians and the agency to prepare for this new program."
Even though this is a further delay -- the program was originally supposed to start this year but was deferred to 2019 -- the ACR praised CMS for shifting from its initial idea of establishing a series of Healthcare Common Procedure Coding System (HCPCS) level 3 G-codes and modifiers; instead, unique consultation identifiers will be used for reporting, which is a much simpler and less onerous approach for providers, according to the ACR.
"We have not been fans of the G-code claims proposal -- it would be really burdensome," Keysor said. "But CMS has decided to scrap this idea and move forward using unique consultation identifiers, and we think that's a good move. It will be worth the wait if they really use the additional time to establish an effective program."
More good news
The ACR outlined other positive aspects of the rule, including the following:
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Less dramatic cuts to IDTF payments. July's proposed MPFS included an estimated 6% decrease in reimbursement for independent diagnostic testing facilities due to practice expense relative value unit (RVU) changes to codes outside of the radiology code set; the final rule outlines an overall estimated impact to IDTFs of 4%.
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Stable mammography payments. In its 2017 rule, CMS increased the professional component payment for mammography slightly and maintained the 2016 technical component rates, rather than proceeding with significant cuts to the practice expense relative value units. CMS did not address this issue in this final 2018 rule: Values for mammography will remain relatively the same.
"The ACR met with CMS staff in March and urged them to maintain the existing payment rates indefinitely and, as such, we are pleased with the values included in the final rule," the college said in a statement.
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Off-campus payment rates. This year, items and services furnished by off-campus hospital outpatient provider-based departments were no longer paid under the Hospital Outpatient Prospective Payment System (OPPS). Instead, CMS paid for these services under the MPFS at 50% of the OPPS rate. Next year, CMS plans to reimburse for these items at 40% of the OPPS rate -- still unfortunate, but it's an increase from the proposed 25% reimbursement rate.
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PQRS. As for the Physician Quality Reporting System (PQRS) program, the rule finalizes a change from reporting nine measures across three National Quality Strategy domains to only requiring reporting of six measures for the PQRS with no domain requirement. PQRS is being replaced by the Merit-Based Incentive Payment System (MIPS) under the Quality Payment Program, according to CMS.
The ACR said it plans to review the entire MPFS final rule in more detail in the coming weeks and will provide a comprehensive summary.
