Multiple Procedure Payment Reduction (MPPR) to the Professional Component of Diagnostic Imaging Services
Background: In response to incorrect perceptions by some policymakers surrounding overutilization of diagnostic imaging services, the practice of radiology has endured substantial reimbursement cuts implemented both through the legislative and regulatory process. In recent years, the Medicare Payment Advisory Commission (MedPAC) and the Centers for Medicare and Medicaid Services (CMS) sought to control imaging growth through reimbursement cuts that impose a Multiple Procedure Payment Reduction (MPPR) to multiple diagnostic imaging services administered by the same physician, to the same patient, during a single office visit. MedPAC and CMS traditionally applied MPPR policies to the technical component of advanced diagnostic imaging services, or the cost of equipment, non-physician personnel, and medical supplies. In theory, MPPR policies are designed to lower Medicare costs and improve program efficiency by modifying multiple payments for duplicative or overlapping services performed consecutively on the same day. Yet, MedPAC took the unprecedented step of recommending the application of an MPPR policy to the professional component of diagnostic imaging services in its June 2011 Annual Report. In July 2011, CMS, after consulting MedPAC’s recommendation, included provisions in the 2012 Medicare Physician Fee Schedule Proposed Rule to impose a 50 percent MPPR to the professional component of select advanced diagnostic imaging services (i.e. CT, MRI, and Ultrasound). Although slightly different from MedPAC’s initial recommendation, CMS’ proposed policy would result in an inappropriate and unsubstantiated reimbursement cut for radiologists. The value of physician-radiologist interpretations of examinations that usually contain hundreds of images, as well as providing the results of these analyses into the final written medical report for the referring physicians, will be severely undermined.
Present Situation: Despite tremendous opposition from the ACR, CMS ultimately included a 25% MPPR reduction to multiple diagnostic imaging services administered by multiple providers within the same group practice, to the same patient, during a single office visit to the professional component of advanced diagnostic imaging services in its final physician fee schedule rule. The Final Rule can be viewed in its entirety here.
ACR's response to the Final Rule can be viewed here.
On October 27th, Representatives Pete Olson (R-TX) and Betty McCollum (D-MN) introduced H.R. 3269, the Diagnostic Imaging Services Access Protection Act of 2011 in the House of Representatives to block the imposition of the MPPR to the professional component of select advanced diagnostic imaging services through the 2012 Final Physician Fee Schedule Rule. Rep. Olson also made a statement in support of the bill for the Record (read it here).
Read a section-by-section breakdown of the Diagnostic Imaging Services Access Protection Act here.
ACR's statement supporting the Diagnostic Imaging Services Access Protection Act can be viewed here.
Following the House’s lead, on April 25, 2012 Senators Ben Cardin (D-MD) and David Vitter (R-LA) introduced S. 2347, the Diagnostic Imaging Services Access Protection Act to also block the imposition of the 25% PC MPPR.
Read a section-by-section breakdown of the Senate version of the Diagnostic Imaging Services Access Protection Act here.
Read a one-page summary of the Senate legislation which highlights the slight differences in comparison to H.R. 3269 here.
ACR’s statement supporting the Diagnostic Imaging Services Access Protection Act can be viewed here.
Issue: Application of an MPPR to the professional component of diagnostic imaging services performed on the same patient on the same day is an arbitrary and imprecise tool to control Medicare spending. This particular recommendation overestimates perceived efficiencies within the professional component, is not supported by sound data, nor was it developed with substantial physician input. Since each imaging study produces its own set of images requiring individual interpretation, the radiologist is ethically and professionally obligated to expend the same amount of time and effort, regardless of the date of service. Because reductions to the professional component primarily impact radiologists who, as referral-based physicians, rarely order the imaging studies they are asked to interpret, CMS’ attempts to impose an MPPR to the professional component of select advanced diagnostic imagines services also fails to adequately address inappropriate utilization. Imposition of this policy will also make it difficult for radiologists to keep free-standing imaging facilities open for business, thus threatening patient access to important diagnostic imaging services.
Take Action: See if your Represenative has agreed to co-sponsor H.R. 3269 by clicking here, and if they have not, please contact them. You can download a template letter here.
See if your Senators have agreed to co-sponsor S. 2347 by clicking here, and if they have not, please contact them. You can download a template letter here.
