CY2022 Medicare Proposed Rules Contain 'Mixed Bag' for Nuclear Cardiology Reimbursement

Since the Centers for Medicare & Medicaid Services (CMS) released the CY2022 proposed rules for the Medicare Physician Fee Schedule (MPFS) and the Hospital Outpatient Prospective Payment System (HOPPS) in July, ASNC's analysts have thoroughly reviewed the documents and concluded the implications for nuclear cardiology are mixed. Here's a summary of the key takeaways.  
Medicare Physician Fee Schedule
ASNC is disappointed that the CY2022 MPFS proposed rule includes a 12 percent cut to reimbursement for CPT Code 78452 - SPECT MPI, multiple as compared to CY2021 July Medicare rates. This proposed payment reduction was driven by cuts to both the conversion factor and the practice expense portion of reimbursement.

Conversion Factor: The conversion factor proposed in the CY2022 Physician Fee Schedule would reduce MPFS reimbursement by 3.75 percent across all specialties. On July 23, ASNC joined the American Medical Association and other medical specialties in a letter asking Congress to maintain the 3.5 percent increase to the conversion factor at least through CY2022 and 2023. Stay tuned to for updates on congressional action on the conversion factor.

Practice Expense: The proposed cuts to practice expense affect nuclear medicine billing rates. These cuts were driven by increased clinical staff costs and equipment update costs that were included as an input to practice expense rates. ASNC will submit substantive comments to CMS on the proposed cuts to both practice expense and the conversion factor. 

Hospital Outpatient Prospective Payment System
ASNC is pleased that the CY2022 proposed rule for HOPPS recognizes the clinical complexity of the services that nuclear cardiologists provide. For example, the proposed reimbursement for new services that combine hybrid PET/CT imaging (e.g., CPT 78431 - Myocardial imaging, positron emission tomography, perfusion study [including ventricular wall motion[s], and/or ejection fractions[s] when performed; multiple studies at rest and stress, w/concurrently acquired CT) proposed reimbursement is at the same level of CY2021 rates of $2,250.50. 

To assist members, ASNC's advocacy team has compiled the proposed versus July 2021 rates for nuclear medicine procedures under the MPFS and the HOPPS proposed rules into two user-friendly charts. DOWNLOAD THE CHARTS

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