August 30 Deadline to Oppose CMS’ Proposed Professional Component Cuts Approaching

CMS has proposed to implement a Multiple Procedure Payment Reduction (MPPR) on the professional component for any combination of CT, MRI, and/or Ultrasound exams beginning January 2012. This MPPR would have broad reimbursement implications, including a 50% reduction when a radiologist interprets two or more exams from any combination of these modalities on the same patient on the same day, the reimbursements will be reduced by 50%.

In the same rule, CMS also indicated it is studying implementing MPPR reductions across all modalities beginning in 2013.

One analysis by an RBMA board member indicates that if enacted, applying the proposed MPPR reductions to CT, MRI, and Ultrasound interpretations could reduce Medicare payments for these modalities by 5% to 7% for hospital-based radiology practices in 2012. If expanded to all modalities in 2013, it could decrease total Medicare payments by 8% to 9.3% for hospital-based radiology practices.

The RBMA is promoting a campaign to contact the CMS to oppose this change, and has provided a draft letter for you and your radiologists to send opposing the MPPR-PC. Be sure to personalize it to reflect your own individual thoughts and ideas since greater weight will be placed on comments in the letters and not volume of form letters.

After accessing the website, please complete the following steps to formally submit your comments:
1. Once you click on the link above, you will be directed to the “Comments” page for CMS.
2. Fill out the information in Section 1 (First Name, Last Name, City, Country, State, Postal Code, Organization Name, and Category).
3. Due to the character limit, we ask that you DO NOT cut and paste the draft letter template into Section 2, but rather type “See Comment Letter Attached.”
4. In order to attach your edited comment letter under Section 3, “Upload File(s),” simply
a. Click “Browse” to find an attachment stored on your computer or other disk.
b. Select the file you want to attach. The name of the file will appear in the blank field in the Attachments section.
c. Click “Attach” to confirm that you have found the correct file.

The RBMA urges, “If you have not done so, you are strongly encouraged to comment because it is crucial for CMS to get as large a response from radiology as possible.”