SNMMI Submits Comments to CMS Regarding CY 2016 Proposed Rules for HOPPS and MPFS

August 26, 2015

On Wednesday, August 26, SNMMI submitted comments to CMS on the CY 2016 Proposed Rules for the Hospital Outpatient Prospective Payment System (HOPPS) and the Medicare Physician Fee Schedule (MPFS). 

In the HOPPS letter, SNMMI commented on proposed APC restructuring for nuclear medicine services, proposed OPPS treatment of new CPT and Level II HCPCS codes, Off‐Campus Provider‐Based Departments, CMS Offset File, and Q9969 Code. As you know, SNMMI met with CMS earlier this year regarding APC restructuring. Unfortunately, SNMMI's recommendations were not included in the proposed rule. Members should consider providing CMS with comments on this important issue. The deadline to submit comments is no later than 5:00 p.m. ET on August 31st. Comments can be submitted at

In the MPFS letter, SNMMI commented on CY 2016 identification of potentially misvalued services, significant RVU reductions, proposed elimination of refinement panels, changes for CT under PAMA, and Appropriate Use Criteria.

Final rules for HOPPS and MPFS will be issued by CMS in November.