A study commissioned by the American College of Radiology® (ACR®) has found Medicare’s impending evaluation and management (E/M) coding policy could lead to a loss of almost $770 million in Medicare payments for medical imaging in the first year of its implementation.
The analysis of impacts by states and U.S. territories by The Moran Company estimated a 9% reduction in total payments for imaging services billed to the Medicare Physician Fee Schedule (MPFS). The first-year impacts range from lows of 9% for 30 states and a high of 13% for the U.S. Virgin Islands. From a financial standpoint, specialty physicians in California would take the biggest hit with an $88 million revenue loss in the first year.
When trended out over a 10-year period, The Moran Company found the loss could reach about $10 billion for all Medicare outpatient imaging services, regardless of medical specialty.

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The ACR requested the study to gain accurate measures of financial impact of changes to E/M coding policy approved by the Centers for Medicare and Medicare Services (CMS) and published in the calendar year 2020 MPFS Final Rule.
The findings reinforce the ACR’s recent message to Congress about the significant negative consequences the impending 2021 CMS E/M policy will have on radiologists and other medical providers that do not frequently bill E/M services.
The ACR is sharing the study with Congress. We also encourage ACR state chapters and our members to share it with their members of Congress with messages concerning inequities in the impending E/M coding policy as well.