Month Date, Year
Ms. Marilyn Tavenner
Acting Administrator
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Attention: CMS-1590-P
P.O. Box 8013
Baltimore, MD 21244-8013
Dear Acting Administrator Tavenner:
As a practicing radiologist, I am writing to express my concerns with a section of the 2013
Medicare Physician Fee Schedule Proposed Rule (CMS-1590-P) that will severely affect my
ability to provide high quality imaging services to patients. In particular, I wish to voice my
staunch opposition to the expansion of the multiple procedure payment reduction (MPPR) to the
professional component (PC) of advanced diagnostic imaging services to the group practice
setting.
CMS’ decision to further expand the PC MPPR policy is, once again, rooted in the incorrect
assumption that there are considerable efficiencies when different radiologists interpret
successive imaging studies during a single patient visit. What minimal efficiencies exist in the
professional component, such as dictating the report and comparing images, when a single
radiologist interprets multiple images from the same patient, during the same session, on
the same day immediately and unequivocally disappear when two different radiologists
review the same set of images. Unfortunately, CMS has once again failed to recognize that
radiologists are morally and professionally obligated to expend an equal amount of time, effort,
and skill interpreting images, irrespective of whether or not previous examinations have been
performed in the same session, without regard to the modality or section of the body under
examination, and regardless of the number of radiologists analyzing the images.
As a physician who specializes in diagnosing both severe injuries and life threatening diseases, I
am deeply troubled by CMS’ continuing use of flawed MPPR policies that are not supported by
any robust data analysis. These reductions in reimbursement grossly undervalue the role of
radiologists within the health care delivery process. As a result, patient access to life-saving
diagnostic imaging services in all settings, including independent practices, community hospitals,
and large academic medical centers, will be severely compromised. It is my understanding that
administrative concerns originally inhibited CMS from imposing this flawed policy through the
2012 Medicare Physician Fee Schedule Final Rule. However, in its attempt to revive this policy,
CMS fails to provide an in-depth explanation of how these administrative concerns were rectified,
thus running counter to CMS’ commitment to transparency. Therefore, it is imperative that CMS
remove this harmful policy from the 2013 Medicare Physician Fee Schedule Final Rule.
Furthermore, many radiology groups, for the purpose of improved patient imaging care, triage
studies to their radiology subspecialists (e.g., neuroradiology, musculoskeletal) for subspecialty
interpretations and reports. With two or more radiologists rendering interpretations and reports,
coders and billers would be confronted by having to re-create the timing of interpretative sessions
to determine whether or not the MPPR applies. There are many imaging scenarios that exist
which put the MPPR and coding edits at odds, presenting a quandary for radiology practices and
Medicare Administrative Contractors (MACs), alike.
CMS must recognize that clinical settings where patients require multiple examinations during
the same session include severe trauma, cancer diagnosis and follow-up as well as stroke, thus
making the overall medical complexity of patients requiring multiple examinations typically
greater than patients requiring single examinations. The findings of a June 2011 study published
in the Journal of the American College of Radiology concluded that efficiencies within the
professional component of advanced diagnostic imaging services are minimal and vary greatly
across modalities. In fact, this peer-reviewed analysis, which was conducted by an expert panel
of radiologists using the American Medical Association Resource-Based Relative Value Scale
Data Manager (AMA RVS) database, demonstrates that efficiencies within the professional
component could account for a payment reduction ranging from a low of 2.96% for computed
tomography (CT) to a maximum of 5.45% for ultrasound. I respectfully challenge the agency to
produce comprehensive, statistical data that validates its decision to further expand the PC MPPR
to the group practice setting.
I appreciate the opportunity to voice my opposition to this section of the 2013 Medicare
Physician Fee Schedule proposed rule.
Sincerely,
First Name Last Name, MD, FACR (if applicable)