February 8, 2016
Insert Payer Info
Dear Insert Name:
As a radiologist practicing in City, State, I am writing to express my concerns with a
recently announced payment policy change that will severely affect my ability to provide
high quality imaging services to patients. In particular, I wish to voice my staunch
opposition to efforts by insert payer name to apply a multiple procedure payment
reduction (MPPR) to the professional component of advanced diagnostic imaging
services administered to the same patient, by the same physician, during the same
session. As a physician who specializes in diagnosing both severe injuries and life
threatening diseases, I am deeply troubled by this latest attempt to grossly undervalue the
role of radiologists within the health care delivery process. I believe that the imposition
of an MPPR policy to the professional component of diagnostic imaging services will
alter the ability of patients to benefit from multiple imaging exams at the same session,
and thereby greatly reduce patient access to independent and community hospital-based
radiology practices. Therefore, it is imperative that insert payer name rescind this
payment policy change immediately.
It appears that insert payer name’s decision to apply an MPPR to the professional
component of diagnostic imaging services is rooted in the incorrect assumption that there
are considerable efficiencies when radiologists interpret successive imaging studies
during a single patient visit. Unfortunately, insert payer name has failed to recognize that
radiologists are morally and professionally obligated to expend an equal amount of time,
effort, and skill on interpreting images, irrespective of whether or not previous
examinations have been performed on the same day, or the modality or section of the
body under examination. Clinical settings where patients will require multiple
examinations on the same day include severe trauma, cancer diagnosis and follow-up and
stroke, making the overall medical complexity of patients requiring multiple
examinations typically greater than patients requiring single examinations. A recent
article published in the Journal of the American College of Radiology (attached) clearly
demonstrates that efficiencies within the professional component of advanced diagnostic
imaging services are minimal and vary greatly across modalities. In fact, this peerreviewed analysis, which was conducted by an expert panel of radiologists using the
American Medical Association Resource-Based Relative Value Scale Data Manager,
demonstrates that efficiencies within the professional component could account for a
payment reduction ranging from a low of 2.96 percent for computed tomography (CT) to
a maximum of 5.45 percent for ultrasound. These findings clearly show that there is an
extreme disconnect between insert payer name’s policy proposal and actual medical
practice. I respectfully challenge insert payer name to produce comprehensive, statistical
data that validates its decision to impose a 25 percent reduction in the professional
component of multiple advanced diagnostic imaging services administered to the same
patient, by the same physician, during the same session.
My colleagues and I remain deeply concerned that these latest proposed cuts to imaging
services will greatly undermine our ability to provide high quality patient care. It is
important that insert payer name recognize that these changes to physician
reimbursement policy are contrary to appropriate clinical practice and not supported by
sound data analysis and, if implemented, will adversely affect patient access. Should you
have any questions, please do not hesitate to contact me either via phone, (XXX-XXXXXXX), or email, firstname.lastname@emailaddress.com, and I will be happy to lend my
expertise.
Sincerely,
First Name Last Name, MD, FACR (if applicable)