On July 19, 2011, the Centers for Medicare and Medicaid Services (“CMS”) published in the Federal Register its CY 2012 Physician Fee Schedule Proposed Rule (“Proposed Rule”). On November 1, 2011, CMS issued its CY 2012 Physician Fee Schedule Final Rule (“Final Rule”), in part, to “address changes to the physician fee schedule and other Medicare Part B payment policies to ensure that our payment systems are updated to reflect changes in medical practice and the relative value of services.” Most notably for providers and suppliers of radiology services, is the expansion of the multiple procedure payment reduction (“MPPR”) policy to the professional component (“PC”) of certain advanced diagnostic imaging services (e.g., CT, MRI and Ultrasound). For a more detailed explanation regarding the MPPR and the Proposed Rule, please see this article published by The HLP founding shareholders, Adrienne Dresevic, Esq. and Carey F. Kalmowitz, Esq.
In response to an overwhelming majority of negative feedback CMS received on the Proposed Rule with respect to the MPPR, CMS determined that a 25% reduction in the PC of second and subsequent advanced imaging services was appropriate (versus the proposed-50% reduction). Therefore, beginning January 1, 2012, the MPRR would apply to the PC of certain advanced imaging services.
Radiology providers and suppliers are being called upon to urge their Representatives to support HR 3269, the “Diagnostic Imaging Services Access Protection Act of 2011,” which, if enacted, would prevent the MPPR from being applied to the PC of imaging services.
For more information, please contact Adrienne Dresevic, Esq. and Carey F. Kalmowitz, Esq. at (248) 996-8510 or (212) 734-0128 or visit diagnostic imaging specialty page on the HLP website.