Advocacy Alert: ASNC Urges CMS to Stop Cut to Proposed Conversion Factor

ASNC has commented to the Centers for Medicare and Medicaid Services (CMS) on proposed changes to the Medicare Physician Fee Schedule (PFS) and Hospital Outpatient Prospective Payment System for 2021.
ASNC's comments urge the Agency to use its administrative authorities to stop a drastic cut to the proposed Medicare PFS conversion factor while also thanking the Agency for being responsive to ASNC's prior advocacy – such as on pricing for the direct practice expenses of myocardial PET equipment and delaying implementation of the AUC mandate. 

Below is a summary of ASNC's key points: 
Medicare Physician Fee Schedule 

CY 2021 Conversion Factor

Noting the impacts of the pandemic on practices and that Medicare payments have failed to keep up with inflation since 1992, ASNC stressed that the Agency's proposed decrease in Medicare's conversion factor could not come at a worse time. ASNC pressed CMS to “take immediate actions to delay or mitigate the cut arising from budget neutrality requirements while allowing the previously finalized evaluation and management (E/M) code policies to take effect on January 1, 2021.” 

Myocardial PET Equipment Inputs 

ASNC thanked CMS for maintaining contractor pricing for the technical component of myocardial PET services (CPT codes 78432, 78459, 78491, and 78492) for 2021 and stressed that this pricing should be continued “until there can be an adequate accounting of all costs associated with the delivery of Myocardial PET.”

In its comments, ASNC also thanked the Agency for responding to requests to update pricing for nuclear rod source set equipment and to remove incorrectly duplicated codes for PET generator (rubidium) equipment. 

Proposed Removal of NCD #220.6.16 FDG PET for Inflammation and Infection

ASNC noted its support for CMS's plan to use the expedited administrative process to remove the national coverage decision for FDG PET for inflammation and infection and thereby allow local Medicare Administrative Contractors (MACs) to determine coverage. ASNC requested conforming change in the Medicare National Coverage Determinations Manual to avoid confusion and “provide clarity as to MAC discretion in covering PET scans.” 

Medicare Appropriate Use Criteria (AUC) Program for Advanced Diagnostic Imaging

While the PFS proposed rule does not mention the AUC Program, ASNC nonetheless commended CMS for not moving beyond the AUC Program's Educational and Operations Testing Period in 2021. We also reiterated ASNC's long-standing position that we do not support full implementation of the Program as set in law.

Hospital Outpatient Department

Cardiac PET and PET-CT New Technology APC Placement

ASNC expressed appreciation of CMS's acknowledgment of nuclear medicine as a clinically unique family that requires special cost inputs around the handling and disposal of radiopharmaceuticals and, consequently, CMS's proposal to maintain PET/CT CPT codes 78431, 78432, and 78433 in the new technology Ambulatory Payment Classification (APC) groups for 2021.

Prior Authorization for Outpatient Department Services

While CMS did not propose use of prior authorization of services of interest to ASNC members and their patients, ASNC used the comment period as an opportunity to emphasize the tremendous burden prior authorization places on physician practices and the barrier it creates to timely patient access to care. In its comments, ASNC stated payment models that put healthcare providers at greater downside risk for quality and cost should be CMS's focus and any use of prior authorization in both original Medicare and Medicare Advantage should require a standard electronic prior authorization process, including the electronic transmission of prior authorization requests and responses, as well as a real-time process for items and services that are routinely approved.

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You can find ASNC's complete comments in the Advocacy Hub. Please take a moment right now to renew your membership, thus ensuring that you will receive ASNC's updates on advocacy and other issues affecting your practice