CMS Comment Letter Template

Richard A. Justman, MD
National Medical Director
United Healthcare
5901 Lincoln Drive
Edina, MN 55436
Dear Dr. Justman:
I am writing to express my strenuous objection to United Healthcare’s (UHC) revision of its Radiology
Multiple Imaging Reduction Policy to include the professional component (PC) of subsequent imaging
services effective in the third quarter of this year as communicated in UHC’s May 2014 Network Bulletin
(starting on page 44).
Application of the Multiple Procedure Payment Reduction Policy (MPPR) to professional services in
radiology mistakenly follows from a gross overestimation of the efficiencies generated by the
interpretation of multiple studies on the same patient. Radiologists expend an equal amount of time,
effort, and skill on interpreting images irrespective of whether they are from a single study or multiple
exams. Patients requiring multiple examinations tend to have more complex conditions that are associated
with such high-risk clinical factors as severe trauma, cancer diagnosis and follow-up, and stroke.
Separate studies published in the Journal of the American College of Radiology found minimal efficiencies
within the professional component of multiple imaging studies when interpreted by the same physician
(ranging from 2.96 percent to 5.45 percent depending on the modality)1 and such efficiencies become
nearly negligible when different physicians in the same practice render the interpretations (1.39 percent to
2.73 percent)2. When presented with these findings, the United States Congress mandated that the
Centers for Medicare & Medicaid Services (CMS) disclose the data and assumptions underlying its own
MPPR-PC policy.
In addition to the flawed assumptions regarding efficiencies in physician work, UHC’s revised policy
presents significant administrative difficulties. 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 with having to re-create the timing of interpretative
sessions to determine whether or not the MPPR applies. Legacy information systems currently lack the
ability to collect and report such information.
I am deeply troubled by UHC’s desire to grossly undervalue the role of radiologists within the health care
delivery process on behalf of your members. I believe strongly in evidence-based decision making, and
this decision to include an MPPR for professional radiology services flies in the face of both the available
evidence and medical practice. I hope that you will reconsider and revise this deeply flawed payment
policy in advance of its imminent implementation.
Professional Component Payment Reductions for Diagnostic Imaging Examinations When More Than One Service Is
Rendered by the Same Provider in the Same Session: An Analysis of Relevant Payment Policy Allen, Bibb et al. Journal of
the American College of Radiology, Volume 8, Issue 9, 610 - 616
Professional Efficiencies for Diagnostic Imaging Services Rendered by Different Physicians: Analysis of Recent
Medicare Multiple Procedure Payment Reduction Policy Duszak, Richard et al. Journal of the American College of Radiology,
Volume 10, Issue 9, 682 - 688