SNMMI Comments on CMS's Proposed Physician Fee Schedule for 2018

September 11, 2017

In the comment letter to CMS on the proposed 2018 Medicare Physician Fee Schedule, SNMMI recommendations include:

finalizing the RUC and specialty society recommendations for work and practice expenses for 78300, 78305, and 78306;
exempting all nuclear medicine- and all DRA-affected imaging services from the proposed 25% reduction;
exempting carrier-priced services from the 25% reduction and conducting code or family analysis in order to prevent access issues or shifting of care due to insufficient payment rates for important nuclear medicine services;
allowing practitioners more time to focus on and adjust to the appropriate use criteria mandate to allow for testing in 2018; and
reducing the regulatory burden on nuclear medicine billing, as the current complexity requires extensive time and training for providers and must also be a burden for Medicare and its contractors.

The comment letter is here, and CMS will publish the final rule around October 1, 2018.