December 2, 2020
Yesterday evening, December 1, the Centers for Medicare and Medicaid Services (CMS) released the calendar year 2021 Medicare Physician Fee Schedule (MPFS) final rule. Although 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 CY 2021 conversion factor is conversion factor is $32.41, a decrease of $3.68 from the CY 2020 PFS conversion factor of $36.09. The decrease will leave the 2021 conversion factor even lower than the 1994 conversion factor of $32.905. Finalizing the PFS without addressing certain inequities will result in access issues for Medicare beneficiaries. The MPFS final 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 acting to mitigate its spread throughout the country, many nuclear medicine practices faced economic hardships. COVID-19 has created substantial negative financial realities and perpetuated uncertainties for health care practices that will generate lasting impacts long after the immediate crisis ends. A survey carried out by SNMMI revealed that nuclear medicine and radiology practices were forced to cease or significantly reduce volumes for important services. 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), approximately 80% of respondents experienced decreases greater than 50% in study volumes (~37% saw a 50% reduction; ~42% saw a 75% reduction). Survey respondents also reported a decrease of almost 40% in important radionuclide therapy volumes, with 14.51% discontinuing these life-saving procedures. It takes no stretch of the imagination to understand the real financial impact that these types of reductions produce on practices.
CMS/HHS has authority under the COVID-19 public health emergency (PHE) declaration to preserve patient access to care and mitigate financial distress due to the pandemic. In our comments, we strongly urge CMS/HHS to utilize that authority to implement office visit increases, as planned, and waive budget neutrality requirements for the new Medicare office visit payment policy. We have also lobbied Congress, individually and through a coalition of medical society industry groups, to waive budget neutrality for the 2021 Medicare Fee Schedule RVU increases. Our latest coalition press release may be found here.
SNMMI and the coalition support H.R. 8702, which would provide two years of much-needed stability for Medicare providers as they continue to strive to meet the needs of patients during this public health emergency. The bill was introduced on October 30, 2020, and has since then been referred to the Committee on Energy and Commerce and the Committee on Ways and Means. A bill summary may be found here. Individuals may contact their members of Congress through an easy-to-use template letter found here.
Although we are hugely disappointed by the cuts to physician reimbursement, the final MPFS rule does provide a silver lining for nuclear medicine. Inputs for myocardial PET were finalized, and contractor pricing was maintained for the technical component.
CMS retired the national coverage determination (NCD) for non-coverage of infection/inflammation effective January 1, 2021. In the absence of an NCD, the coverage determinations for PET for infection and inflammation will be made by Medicare Administrative Contractors (MACs). The society is pleased with this expansion of non-oncologic PET coverage, as the society’s leadership, staff and consultants held multiple in-person meetings and conference calls with the Coverage and Analysis Group at CMS to remove this NCD. Although our ultimate goal is to get CMS coverage for all the approved PET indications, this is a pivotal first step.