SNMMI Sends CMS Comments on Proposed 2020 Hospital Outpatient Payment Regulation

September 9, 2019

SNMMI has submitted a comment letter to CMS on the proposed rule for the 2020 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:

  • Recommend Placements for New and Revised Nuclear Medicine CPT codes effective January 1, 2020
    • Placement of CPT codes 78803 in APC group 5593 rather than APC 5592
    • Placement of CPT codes 78X29, 78804 and 788X1 into APC group 5594
    • CPT 78X32 be placed in APC 1522, CPT 78X33 in APC 1523 and CPT 78X34 in APC 1523
  • Add-on Payments for non-LEU Sourced Radiopharmaceuticals
    • Requests that CMS finalizes the continuation of separate payment for Q9969 for CY 2020

CMS will publish the final rule around November 1, 2019.

You can read SNMMI's comment letter here. Members are encouraged to send comments to CMS on or before the September 27th deadline. For more information on how to get involved, contact SNMMI Health Policy staff at