October 13, 2020
On Friday, SNMMI and several medical societies sent a joint letter asking Congress to waive budget neutrality for the relative value unit (RVU) increases in the CY 2021 Medicare Physician Fee Schedule (MPFS). The Centers for Medicare and Medicaid Services (CMS) Proposed CY 2021 MPFS Rule increased payment rates for evaluation and management (E/M) codes; however, because of budget neutrality imposed by Congress, increases in E/M payment rates would lead to huge deficits in other payment rates.
Although SNMMI agrees with the adoption of the new 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. The MPFS proposed rule will also negatively impact our membership who, to a large extent, provide few 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 urged 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. Now, we are working on the legislative end, requesting Congress to waive budget neutrality for the 2021 Medicare Fee Schedule RVU increases.