RBMA offers comments on 2015 Medicare fee schedule

The Radiology Business Management Association (RBMA) has published its comments on the final 2015 Medicare Physician Fee Schedule (MPFS), noting that it contains a number of items of concern for RBMA members.

Published in the Federal Register on November 13, the final 2015 MPFS rates in general contained few cuts to radiology reimbursement, and even scaled back steeper cuts proposed in July for radiation oncology services. The final rule also included new CPT codes for digital breast tomosynthesis (DBT).

In its analysis, RBMA said it was concerned that the U.S. Centers for Medicare and Medicaid Services (CMS) did not take the group's advice on adjusting equipment maintenance costs, which RBMA believes were underestimated in the proposed MPFS rule in July. RBMA believes the rates should be raised to 15% for mammography equipment and 10% for all other equipment.

RBMA applauded the establishment of G-codes for DBT reimbursement. CMS plans to review all mammography codes, including G-codes and CPT codes with the exception of breast tomosynthesis, for revaluation.

Among other comments made by RBMA:

  • The final rule highlights the need to replace the flawed sustainable growth rate (SGR) formula with a permanent solution.
  • RBMA disagrees with the CMS decision to use the price of a desktop computer as a proxy for the cost of replacing a PACS workstation. RBMA had asked for a one-year delay in CMS' effort to transition from film to digital practice expense inputs.
  • Radiology will see a combined average 1% reduction in total Medicare-allowed charges for services covered by MPFS, and independent diagnostic testing facilities (IDTFs) will see a 2% reduction.
  • CMS did not act in several areas of concern to radiology, including payments for secondary interpretation of images, revising policies for billing of substitute physicians, and using Medicare expenditures of $10 million or more as a screen for potentially misvalued services.
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