CMS 2012 Proposed Medicare Physician Fee Schedule

August 12, 2011

August 8, 2011

To:  Nebraska Radiological Society Members

From: Thomas Dworak, MD, President

RE:  CMS 2012 Proposed Medicare Physician Fee Schedule (CMS-1524-P)

Nebraska Radiological Society Members are being strongly urged to contact the Centers for Medicare and Medicaid Services (CMS) to oppose the application for a multiple procedure payment reduction (MPPR) to the professional component (PC) of advanced diagnostic imaging services administered to the same patient, by the same physician, during the same session.  This decision would impose a 50% reduction in the professional component of the above services.

CMS’ MPPR-PC proposal was in its 2012 Medicare Physician Fee Schedule proposed rule (CMS-1524-P) and will severely affect radiologists’ ability to provide high quality imaging services to Medicare patients.  The CMS-1524-P proposed rule may be found at the following link: https://www.cms.gov/PQRS/Downloads/2012_NPRM_PFS_Proposed_Rule508.pdf

CMS’ decision to apply an MPPR to the professional component of diagnostic imaging services is rooted in the incorrect assumption that there are considerable efficiencies when radiologists interpret successive imaging studies on the same patient during the same session.  Unfortunately, CMS has failed to recognize that radiologists expend an equal amount of time, effort, and skill in interpreting images, regardless of whether or not previous examinations have been performed on the same day, or the modality or section of the body under examination.

Attached please find a sample draft letter, which we would ask members to model in reflecting your thoughts and ideas in your opposition letter.   While CMS will count the number of letters it receives, greater weight will be given to those comments not appearing as form letters.

Once your letter is complete it may be sent to CMS via one of the following ways:

Electronically:  http://www.regulations.gov (follow the instructions for “submitting a comment”)

Mail:

Donald Berwick, MD

Administrator

Centers for Medicare and Medicaid Services

Department of Health and Human Services

Attention:  CMS-1524-P

PO Box 8013

Baltimore, MD 21244-8013

**If possible please also forward a copy of your letter to the NRS office.

The Nebraska Radiological Society appreciates your support and response to this initiative and I would strongly encourage you and your colleagues to consider sending a letter to CMS opposing the MPPR-PC.  The deadline to submit comments to CMS is August 30, 2011.

Please feel free to contact myself or the NRS office with any additional questions or concerns regarding this issue.

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