September 18, 2019
The Centers for Medicare and Medicaid Services (CMS) released the calendar year 2020 Medicare Physician Fee Schedule (MPFS) and Hospital Outpatient Prospective Payment System (HOPPS) proposed rules in July. Some of the changes proposed greatly impact nuclear medicine and molecular imaging reimbursement.
The society—along with the American College of Nuclear Medicine—have already submitted comments alerting CMS to the impact of these proposals. We need your help in submitting comments as well. CMS needs to hear how these proposals impact your profession and patient care. This is your chance to be heard!
CMS uses the Medicare Physician Fee Schedule to reimburse physician services. The MPFS is financed by Part B and comprises resource costs associated with physician work, practice expense, and professional liability insurance.
CMS uses the HOPPS to reimburse for hospital outpatient services. The HOPPS was created to minimize beneficiary copayments in response to rapidly growing Medicare expenditures for outpatient services and large copayments being made by Medicare beneficiaries. Outpatient services covered belong to an APC group. Each group of procedures (i.e., codes) within an APC is presumed to be “similar clinically and with regard to resource consumption.”
For Providers Billing in the Hospital Outpatient Setting- HOPPS
SNMMI and ACNM recommend improvements in the way that CMS pays hospital outpatient departments for nuclear medicine and molecular imaging procedures.
Send your own personalized comment—with any of the points noted above—to CMS directly, adding your own comments on the impact of these proposals, including the impact on patient care from your perspective.
The letter includes our strong requests to:
Please send your comments on HOPPS to CMS before September 27 at 5 pm ET.
For Providers Billing in the Medicare Physician Fee Schedule -MPFS
SNMMI and ACNM has submitted a comment letter on the proposed rule for the MPFS recommending corrections in the way that CMS calculates the inputs and accepts invoices for use in the payment formula for the new CPT codes for nuclear medicine and molecular imaging procedures, specifically for CY 2020 myocardial PET and SPECT and SPECT-CT procedures. Many thanks to those members who provided additional invoices, which we included in our submissions as a summary table and supplemental materials.
In response to alarming proposed reimbursement cuts to cardiac PET included in the proposed 2020 Medicare Physician Fee Schedule, SNMMI, ACNM, ASNC and ACC partnered to launch a robust advocacy effort, asking for support from Congress and providing compelling information and data to CMS on the true cost of providing cardiac PET.
The letter includes our strong requests to CMS:
Professional Component Recommendations
Technical Component Recommendations
Please send your comments on MPFS to CMS before September 27 at 5 pm ET.
Additional Resources:
Background regarding the new and revised 2020 CPT codes
SNMMI-ACNM Comments on 2020 Medicare Physician Fee Schedule
SNMMI-ACNM Comments on 2020 Hospital Outpatient Prospective Payment System
SNMMI Webinar and Highlights on 2020 Code Updates and Changes
CMS will publish both HOPPS and MPFS final rules around November 1, 2019. SNMMI will notify our members via our web site and notices when they are available. Thank you for your help!