ACR finds favorable signs in 2018 MPFS proposed rule

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The American College of Radiology (ACR) has found several things to like in the proposed rule for the 2018 Medicare Physician Fee Schedule (MPFS). The U.S. Centers for Medicare and Medicaid Services (CMS) has backed down on a threatened mammography payment cut, while giving radiology a breather on using clinical decision support.

The biggest piece of good news with the 2018 MPFS is that the proposed rule does not move forward with a 50% cut to the technical component of mammography services, which was suggested in the 2017 rulemaking process, the ACR said. The new proposed rule also delays implementation of reporting with clinical decision support (CDS) based on appropriate use criteria.

The rule includes a conversion factor of $35.9903, a slight uptick from the current conversion factor of $35.7551. This change reflects a 0.5% update required by the Medicare Access and CHIP Reauthorization Act (MACRA), a budget neutrality adjustment, and a 0.3% target recapture adjustment, according to CMS.

What's the bottom line? Overall, the rule proposes a 1% decrease to radiology and interventional radiology payments and no decreases for nuclear medicine. Radiation oncology and radiation therapy would actually see a 1% payment increase.

Mammography payments stable

In its 2017 rulemaking cycle, CMS increased the professional component payment for mammography slightly and maintained the 2016 technical component rates, rather than proceeding with significant cuts to the practice expense relative value units (RVUs). CMS did not address this issue in the proposed rule for 2018, according to the ACR, but listed values for mammography that are the same as its 2017 values.

"The ACR met with CMS staff in March and urged them to maintain the existing payment rates indefinitely and as such, we are pleased with the values included in the proposed rule," the college said in a statement.

More time for CDS

More good news is that the proposed rule pushes back the start date for implementing clinical decision-support reporting based on appropriate use criteria (AUC) from January 2018 to January 2019. In fact, CMS is proposing what it calls an "educational and operations testing period" for one year that would start on January 1, 2019. During this testing period, ordering physicians would consult appropriate use criteria tools and physicians furnishing the exam would report AUC consultation information when submitting the claim -- although CMS would pay claims even if this information was not included.

CMS also plans for a voluntary reporting period to begin in July 2018, depending on whether the Medicare claims system is ready to accept and process claims that include AUC consultation information, the ACR said.

The college will be watching how CMS decides to process the AUC consultation information, ACR Executive Vice President Cynthia Moran told

"We're generally hopeful that CMS is on the right track for implementation of the AUC program, going live in January 2019, but we do have concerns about how they propose to process the AUC consultation on claim forms, so we will be addressing those issues with them," she said.

CMS has listed qualified CDS mechanisms on its website, including the National Decision Support Company's CareSelect program, according to the ACR.

Analog x-ray phaseout

The proposed rule also outlines a payment incentive for the transition from traditional analog x-ray imaging to digital radiography: Starting in 2018, technical component imaging service payments for traditional x-rays will be cut by 7%; in 2023 and beyond, this cut will be 10%. To catch these exams, CMS will establish a new modifier to report traditional x-ray imaging, the agency said.

Close review

The ACR said it plans to review the entire proposed MPFS rule in the coming weeks, and it will submit comments by the September 11 deadline.

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