ASNC submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed rules for the 2025 Hospital Outpatient Prospective Payment System (HOPPS) and the Medicare Physician Fee Schedule (MPFS). 

Key points from ASNC's comments to CMS on both proposed rules are detailed below. Stay tuned for additional details and calls to action. 

On HOPPS: ASNC Weighs in on CMS Proposal for Radiopharmaceuticals Reimbursement

ASNC offered a detailed response to CMS's proposal to unbundle reimbursement for high-cost radiopharmaceuticals from payments for the services in which they are used. ASNC accepts CMS’s proposal to move forward with a $630 payment threshold but also reminds CMS that lowering this threshold could lead to greater cuts to nuclear cardiology reimbursement. This policy would mean that any radiopharmaceuticals with a per-day cost over $630 would be paid separately from the procedure in which it is used. This threshold would cause a modest decrease in the nuclear medicine ambulatory payment classifications (APCs); however, previous versions of the proposed policy would have had much larger negative impacts on the nuclear medicine APCs. For example, an earlier proposal from CMS would have set the threshold at $140 dollars and resulted in more significant cuts to the nuclear medicine APCs. ASNC is urging CMS to work closely with stakeholders to monitor for any negative impact on nuclear cardiology services if the policy is finalized.

HOPPS Proposed Rule on PET/CT: If finalized, payment rates for the PET/CT high-volume code 78431 would remain stable while reimbursement for 2 less frequently billed codes, 78432 and 78433, would increase.

ASNC recently developed a resource on hospital billing that explains how CMS uses hospital claims data and cost reports to develop reimbursement rates. Members are encouraged to review the resource to understand how data submitted by hospitals today could impact reimbursement in 2 years.

ASNC supported CMS’s proposals to reassign PET/CT codes to different APCs and provide an add-on payment for domestically sourced Mo-99 starting Jan. 1, 2026.

Read ASNC's Comments on the HOPPS Proposed Rule for 2025.

On MPFS: ASNC Warns Pay Cuts Would Impact Patients' Access to Care

In response to the proposed rule for 2025 physician payment rates and other policies in the MPFS, ASNC submitted comments to CMS warning that cuts to physician reimbursement threaten patients' access to care. ASNC called on CMS to refrain from policy changes, including proceeding with a new primary care hybrid payment model, until Congress reforms the Medicare physician payment system and revises the current budget-neutrality rules that have led to recent payment cuts. ASNC offered support for telehealth proposals, although extending the COVID-era telehealth flexibilities beyond 2024 requires action from Congress.

ASCVD: On CMS’s proposals to allow payment for atherosclerotic cardiovascular disease (ASCVD) risk assessment and management codes, ASNC was supportive but asked CMS to clarify whether a patient with a high coronary artery calcium score would be considered as already having a cardiovascular disease diagnosis for the purpose of billing for risk assessment or management services. Under CMS’s proposal, physicians could not bill the new codes if a patient already has a cardiovascular disease diagnosis or a history of heart attack or stroke.

Read ASNC's Comments on the MPFS Proposed Rule for 2025.

Up Next: CMS will release the 2025 HOPPS and MPFS final rules in November. Stay tuned to ASNC for analysis of the impact of CMS’s final policies on nuclear cardiology.