SNMMI Submits Comments to CMS on Physician Fee Schedule and Hospital Outpatient Payments

September 20, 2023

Last week SNMMI and ACNM submitted comments to the Centers for Medicare & Medicaid Services (CMS) on its proposed rules for the 2024 Physician Fee Schedule (PFS) and Hospital Outpatient Prospective Payment System (OPPS). As the organizations that set the standard for molecular imaging and nuclear medicine practice, SNMMI and ACNM appreciate the opportunity to provide comments to assist CMS in further refining the PFS payment policies.

The letters focus on the issues below, which are of interest and importance to SNMMI and ACNM members.

Physician Fee Schedule

In this letter, SNMMI and ACNM focused on 5 specific issues with the proposed rule.

  • CMS should work quickly to resume the appropriate use criteria for advanced diagnostic imaging programs.
  • CMS should retain measure #147 (“Nuclear Medicine: Correlation with Existing Imaging Studies for All Patients Undergoing Bone Scintigraphy”) under the Medicare Quality Payment Program. Otherwise, it would effectively exclude nuclear medicine practitioners from the QPP, given that this is the only MIPS measure applicable to them. 
  • CMS should further refine the utilization assumptions in the evaluation and management add-on code to prevent unwarranted reductions in the Medicare conversion factor.
  • CMS should retire the NCD on NaF-18 PET for identifying bone metastasis of cancer.
  • CMS should refine its Medicare provider and supplier enrollment proposals: SNMMI and ACNM have significant concerns that the proposals are overbroad in places, may unfairly or unnecessarily subject providers and suppliers to enrollment revocation or denial procedures, and will be difficult to navigate without further clarification.

Click here to read the full letter.

Hospital Outpatient Prospective Payment System

In this letter, SNMMI and ACNM comment on three issues within the proposed rule.

  • OPPS packaging policy for diagnostic radiopharmaceuticals:
    • CMS should pay separately for diagnostic radiopharmaceuticals that exceed the per day cost threshold for drugs.
    • Alternatively, CMS could apply a higher cost threshold to more specifically target certain high-cost diagnostic radiopharmaceuticals.
    • CMS should not adopt other possible approaches discussed in the proposed rule at this time.
  • CMS should not finalize the proposed assignments for cardiac PET/CT studies (APCs 1522 and 1523) for 2024, which are not consistent with the resources needed to perform these services. Instead, we recommend that CMS assign codes 78341, 78432, 78433 to APC 1523.
  • CMS should not develop or adopt measures specific to AI, because each application is unique.

Click here to read the full letter.