On July 1, 2011, the Centers for Medicare and Medicaid Services (CMS) released the proposed Medicare Physician Fee Schedule (PFS) for 2012.

Issue Brief — The Role of Congress in Physician Payment

Reimbursement Alert

CMS Releases Final 2010 Physician Payment Rule

SCCT Working to Fight Proposed Cuts in Reimbursement

CMS Releases 2010 Proposed Rule

• Conversion Factor: For 2010, CMS is projecting a conversion factor of $28.3208 and a PFS update of -21.5 percent. The conversion factor for 2009 is $36.0666. Congress has taken a series of legislative actions to prevent deep reductions in payment over the last several years. As of this writing, some proposals in Congress call for a 2 or 3 percent positive payment update for physician services. SCCT is working in coalition with others in the House of Medicine to urge Congress to prevent the -21.5 percent cut.



• What does this proposal mean to you? A cut in payment rates for all services provided under Medicare.



• Practice Expense: CMS is proposing changes to practice expense and plans to change the complex reimbursement formula based on data recently obtained from the American Medical Association's (AMA) Physician Practice Information (PPI) Survey. The AMA survey data show steep declines in practice expense for nearly all cardiology and radiology services. With the exception of some evaluation and management services, nearly all services that cardiologists perform would see cuts ranging from 10 percent to more than 40 percent for individual services. For example, cardiac MRI and echocardiography would face cuts of up to 42 percent. Given that cardiovascular CT angiography is reported with Category III tracking codes, the proposed rule does not assign any reimbursement values. We will learn the assigned values when CMS publishes the final fee schedule for 2010, by November 1, 2009. The final rule will provide SCCT and others the opportunity to comment on assigned values for cardiovascular CT angiography.



• What does this proposal mean to you? Additive cuts to those above for the practice expense component (clinical staff, supplies and equipment) of services provided under Medicare.



• Equipment utilization: CMS proposes changes to the formula for calculating the per-procedure cost of medical equipment costing more than $1 million. Specifically, CMS proposes to increase this equipment utilization rate assumption from 50 percent of the time practices are open for business, to 90 percent, thus driving down the practice expense for services using that equipment. At this time CMS does not propose to implement a change for less expensive equipment. However,legislative proposals on Capitol Hill would establish a 75 percent equipment utilization assumption rate spread across all imaging modalities. Sweeping and unsubstantiated changes in equipment utilization will to have a big impact on cardiac CT services. SCCT will provide substantial comments to CMS. In addition, we are in communication with lawmakers about this flawed proposal.



• What does this proposal mean to you? Yet another cumulative cut in practice expense reimbursement rates as CT equipment exceeds the million dollar price determined by CMS.



• Malpractice: CMS proposes to update the malpractice Relative Value Units (RVU) with data from a new survey of specialty-level malpractice premiums. In addition, CMS has proposed a new method for determining malpractice RVUs for technical component services. The proposed new malpractice RVUs would reduce cardiology and radiology payments by 1 percent.



• What does this proposal mean to you? An additive cut to reimbursement rates in 2010.



• Quality: The proposed rule contains a number of provisions to promote improvement in quality of care and patient outcomes through revisions to the Electronic Prescribing Incentive Program (e-Prescribing Program) and the Physician Quality Reporting Initiative (PQRI). Eligible professionals or group practices that meet the requirements of each program in CY 2010 will be eligible for incentive payments for each program equal to 2.0 percent of their total estimated allowed charges for the reporting periods



• What does this proposal mean to you? Potential opportunity for bonus payment from Medicare if initiative requirements are met.



• Accreditation: CMS, in an effort to begin implementation of a statutory provision of last year's Medicare reform law, has proposed detailed requirements to guide the mandatory accreditation of facilities that provide imaging services. This provision applies to advanced diagnostic imaging services including MR, CT, nuclear and PET. Accreditation is mandated to take effect January 1, 2012.



• What does this proposal mean to you? Accreditation is required for CT no later than January 1, 2012.