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ACR asks CMS to scrap multiple procedure cuts

by Brendon Nafziger, DOTmed News Associate Editor | September 02, 2011
The American College of Radiology asked the Centers for Medicare and Medicaid Services to scrap proposed reimbursement cuts to doctors performing multiple imaging scans on the same patient during the same visit.

In a letter sent to CMS Tuesday, the group, which represents 34,000 radiologists and radiation oncologists, called CMS' rationale for the cuts "unfounded."

In a proposed rule for the 2012 Medicare physician fee schedule, the professional component of Medicare reimbursement for doctors performing an MRI, CT or ultrasound scan on the patient on the same day will be cut by 50 percent. Currently, CMS cuts only the technical component for multiple procedures.
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ACR says there are no more than 5 percent efficiencies when the multiple exams given to the same patient are interpreted so the cuts are excessive.

"CMS' decision to apply an [multiple procedure payment reduction] 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," the group wrote in the letter to Donald Berwick, the CMS chief.

"However, radiologists are morally and professionally obligated to expend an equal amount of time, effort and skill on interpreting images, regardless of whether or not a previous examination has been performed on the same day. Each imaging study produces its own unique set of images that must be interpreted in its entirety, separately dictated and written in separate reports to the referring physicians."

ACR said clinical settings where multiple procedures happen tend to be medically complex, including severe trauma, cancer diagnosis and stroke.

Also, rural patients who live away from imaging centers sometimes schedule several examinations on the same day.

The CMS proposal partly derives from a 2009 Government Accountability Office report, which ACR says "mischaracterizes" multiple procedure efficiencies. The only service combination the GAO considered was that of CT scans of the abdomen and pelvis, which are nearly always performed together and yield "the highest level of efficiency that could possibly be attained when two diagnostic imaging examinations are performed together."

In fact, a study published online in June in the Journal of the American College of Radiology found only modest efficiencies for multiple procedures. The average relative contributions for pre- and post-service work ranged from 20 percent in CT to 33 percent in ultrasound, and the maximum percentage of duplicated pre- and post-serve work goes from 19 percent in nuclear medicine to 24 percent in ultrasound. This translates to, at maximum, professional fee schedule reductions of 2.96 percent in CT to 5.45 in ultrasound, the study said.

In the letter, the doctors group also said radiologists who met with Berwick during a recent visit in Minnesota said he told them there "aren't many efficiencies" when interpreting multiple exams.

The CMS' final rule is due later this year.

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