The Moran report used Medicare claims data and 2006 payment rates from the CMS Physician Fee Schedule and Hospital Outpatient Payment System to make cross-site spending comparisons and to assess the DRA reductions in relation to the costs of performing the procedures. It also factored-in the expected volume in both the physician-office and hospital outpatient settings. The analysis did not take into account proposed CMS changes in the physician fee schedule or the hospital outpatient payment system that the agency published in 2007.

The Moran study also provides additional insight about a number of issues surrounding the DRA-'05 imaging cuts:


* The study findings contradict the widely-held view that the physician fee schedule has provided excessive payments for medical imaging services when compared to the hospital outpatient payment system. As noted, overall imaging spending in the two systems is virtually identical-at least until the DRA cuts go into effect. The study concludes that "current payment policy, prior to the application of the DRA caps, does not exhibit a bias toward higher payments in one setting versus another."

* The study findings also contradict the view that imaging payments under the hospital outpatient payment system more accurately reflect the actual costs of performing imaging procedures than do the rates under the office-based system. As noted, the study finds that 126 of 145 codes whose prices would drop to the hospital outpatient level would be paid below the estimated costs of performing the procedures in the office setting.

"This is point-blank proof that Congress needs to pass the Access to Medicare Imaging Act [HR 5704, S 3795] to delay these cuts so GAO can figure out just what the impact on patients will be," stressed Trysla.

Copies of the study are available at the Access to Medical Imaging Coalition website: www.imagingaccess.org.

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