A new proposal of the 2022 MPFS could result in higher clinical labor wages and lower reimbursement for radiology and other specialties

New CMS proposal could deal 'significant' cuts to radiologist reimbursements

August 17, 2021
by John R. Fischer, Senior Reporter
Cuts in reimbursement may be on the horizon for radiology and other specialties if a new proposal in the 2022 Medicare Physician Fee Schedule gets the green light from Congress.

CMS has proposed in the 2022 Medicare Physician Fee Schedule to update wages for clinical labor staff. Such expenses, along with medical supplies and equipment costs are budget neutral, meaning that an increase in one payment leads to a proportional decrease in the other component payments.

Robert Still, executive director of the Radiology Business Management Association, told HCB News that if passed, the new rule would have negative repercussions for a broad range of patients. “Specifically those that can least afford potential cuts to services. Again in 2022, as in 2021, CMS proposed payment policies are driven by outdated formulas that do not reflect the current economic conditions in radiology and other subspecialties.”

The updated labor wages would result in an estimated 5% cut for interventional radiology and 1% cut for radiology, according to CMS. Taking into account adjustments for the conversion factor in calculating reimbursement, mandated sequestration and cuts to practice expense values, brings those estimates to 9% and 2%, respectively.

The American College of Radiology said in a statement that specialties like interventional radiology and radiation oncology “are slated for potentially significant reimbursement reductions” due to their high medical supply and equipment costs and lower clinical labor costs.

The cause, according to the Society of Interventional Radiology, is the failure of the federal government to align labor rates and product tables with inflation. “As a result, the profound cuts will negatively affect health equity in communities who have already been particularly hard hit by the COVID-19 pandemic,” it said.

It instead advises Congress and CMS to reverse the cuts, suspend sequestration and maintain the COVID-related increase to the conversion factor to ensure radiology reimbursement remains intact.

Meanwhile, the CardioVascular Coalition, which consists of physicians, other providers, advocates and manufacturers, says that while updating clinical labor wages in the CMS database “makes sense,” there will be a 20% decrease in revascularization services and that the hardest hit practices include cardiology, vascular surgery, venous, radiation oncology and radiology. “The decrease in access to revascularization services could lead to higher amputation rates and exacerbate inequities that already exist, particularly in America’s communities of color.”

Radiologists faced a similar challenge last year with the Medicare Physician Fee Schedule Proposed Rule in 2021, which called for a new coding structure for E/M services. As a result, reimbursement would be cut across the board by 10.61% from $36.0896 to a rate of $32.2605.

Payment cuts tied to budget neutrality were avoided, however, due to a temporary 3.75% increase passed by Congress in the physician fee schedule conversion factor. This increase is set to expire on January 1, 2022. ACR and 108 other organizations requested last month that the increase be retained through 2023. “Maintaining this level of funding will ensure physicians and other healthcare providers can continue to provide high-quality care focused on engaging patients, increasing the delivery of integrated, team-based care, expanding chronic disease management, and reducing hospital admission/readmission rates for beneficiaries residing in the community as well as those in long-term nursing facilities,” they said in a letter to Congress.

Regarding the current proposal, Still says a coalition of nearly 100 subspecialties will again work this year to advocate against such cuts, especially as Medicare beneficiaries continue to face high risks of contracting COVID and other diseases during the pandemic. “We will be asking Congress to reverse these cuts by suspending sequestration and funding the increase in a reasonable conversion factor.”