SNMMI Comments on 2021 MPFS Proposed Rule

September 30, 2020

On Monday, August 3, the Centers for Medicare and Medicaid Services (CMS) released the calendar year 2021 Medicare Physician Fee Schedule (MPFS) proposed rule. Though SNMMI agrees with the adoption of the new evaluation and management (E/M) coding structure recommended by the American Medical Association (AMA), this will result in significant payment reductions to nuclear medicine (~8%) and radiology (~11%) services unless the government removes the budget neutrality requirements. The planned decrease in the 2021 conversion factor will be below the 1994 conversion factor of $32.9050 — which is worth approximately $58.02 today. Finalizing the PFS without addressing certain inequities using other funding mechanisms will result in access issues for Medicare beneficiaries and further drive independent physicians and other health care providers towards market consolidation. The MPFS proposed rule will also negatively impact our membership who, to a large extent, do not provide E/M services. 

As a result of confronting the novel coronavirus in hot-spot areas and mitigating the spread throughout the country, many nuclear medicine practices faced economic hardships. COVID-19 has created substantial financial negative realities and continued uncertainties for health care practices that will generate lasting impacts long after the immediate crisis ends. Nuclear Medicine and Radiology practices were forced to cease or significantly reduce volumes for performing important services, our survey revealed. Almost 93% of respondents saw a decrease in diagnostic nuclear medicine imaging study volumes as a result of COVID-19. For conventional nuclear medicine procedures (other than PET), about 80% experienced decreases greater than 50% in study volumes (~37% saw a 50% reduction; ~42% saw a 75% reduction). Survey respondents also reported almost a 40% decrease in important radionuclide therapy volumes, with 14.51% halting all of these life-saving procedures. It does not take a stretch of the imagination to understand the real financial impacts these types of reductions produce.

In our comments, we strongly urge CMS/HHS to utilize its authority under the COVID-19 public health emergency (PHE) declaration to preserve patient access to care and mitigate financial distress due to the pandemic by implementing the office visit increases as planned while waiving budget neutrality requirements for the new Medicare office visit payment policy. Notwithstanding, SNMMI is supportive of requests to Congress to waive budget neutrality for the 2021 Medicare Fee Schedule RVU increases.   

While the SNMMI is preparing to submit an organizational comment letter covering the breadth of the entire proposed rule, you can help amplify our message relating to the updated E/M policy by submitting individual comments to CMS through this link. The CY 2021 proposed Medicare physician fee schedule chart may be found here.