SNMMI Sends CMS Comments on Proposed 2018 Hospital Outpatient Payment Regulation

September 11, 2017

SNMMI has submitted a comment letter to CMS on the proposed rule for the 2018 Hospital Outpatient Prospective Payment System, recommending improvements in the way that CMS pays hospital outpatient departments for nuclear medicine and molecular imaging procedures. The letter includes requests to:

  • reconsider developing separate payment for diagnostic radiopharmaceuticals or develop separate APCs for groups of diagnostic radiopharmaceuticals (as proposed in our letter and meeting in February 2015),
  • keep CPT codes 78018, 78110, 78111 and 78121 in the new APC groups in order to ensure stability within the coding structure,
  • maintain the pass-through status for 19 drugs and biologics on December 31, 2017, in order to complete the IDEAS study and streamline billing procedures for those studies,
  • not further reduce payments for items and services furnished in newer off-campus, provider-based departments (PBDs), and
  • publish HCPCS code Q9969 volume and cost data in the proposed and final rule for "Drug Blood Brachy Cost Statistics” filed yearly.

CMS will publish the final rule around October 1, 2018.

Read the SNMMI Comment Letter.