Practice Management

CMS has issued the Medicare Physician Fee Schedule (MPFS) Proposed Rule for CY 2024.  Here is a quick summary of major provisions:

Some quick follow-up and highlights (lowlights) from MPFS.

MPFS rough math

Conversion Factor Cut: -3.36%

Diagnostic Radiology (Specialty Table) Cut: -3%

PAYGO (traditionally waived): -4%

Total potential cut to radiology including PAYGO: -10.36% 

Virtual supervision

Extended through 2024

CDS 

Indefinite delay: "Taken together and, in particular, due to the inability of the Medicare claims processing system to automate claims processing edits that ensure only claims subject to the AUC program requirements as prescribed in section 1834(q) of the Act will be processed as such, returned or denied accordingly, we believe the inherent risks in terms of data integrity and accuracy, beneficiary access, and potential beneficiary financial liability for advanced diagnostic imaging services render the AUC program impracticable, and have led us to our proposal to pause efforts to implement the AUC program for reevaluation and rescind current regulations. Working within the parameters prescribed under section 1834(q) of the Act, we have not identified any practical way to move the AUC program forward beyond the educational and operations testing period. Further, without a way forward to fully implement the AUC program, we believe there is no utility in continuing the educational and operations testing period. We will continue efforts to identify a workable implementation approach and will propose to adopt any such approach through subsequent rulemaking. We note, and discuss further below in this section of the proposed rule, that clinical decision support tools can be beneficial in assisting with clinical decision making and we encourage continued use of clinical decision support in a manner that best serves and assists clinicians."

Again, there are proposed cuts to radiology of >10%.  It is also significant that CMS is rescinding the current AUC/CDS regulations. 

The RBMA Federal Affairs Committee will begin a thorough review and draft comments on behalf of the membership.

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Robert Still FRBMA
Executive Director
Radiology Business Management Association (RBMA)
Fairfax VA
(703) 621-3363
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Good morning RBMA members:  The PAYGO section of the cuts was waived through 2024 as part of last year's Consolidation Appropriations legislation, therefore, the total cuts at present calculation are closer to (6%) for 2024.

Please note that there is a correction in the total amount of cuts proposed in the MPFS proposed Rule.  

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Robert Still FRBMA
Executive Director
Radiology Business Management Association (RBMA)
Fairfax VA
(703) 621-3363

Original Message:
Sent: 07-13-2023 18:29
From: Robert Still
Subject: MPFS Proposed Rule

CMS has issued the Medicare Physician Fee Schedule (MPFS) Proposed Rule for CY 2024.  Here is a quick summary of major provisions:

Some quick follow-up and highlights (lowlights) from MPFS.

MPFS rough math

Conversion Factor Cut: -3.36%

Diagnostic Radiology (Specialty Table) Cut: -3%

PAYGO (traditionally waived): -4%

Total potential cut to radiology including PAYGO: -10.36% 

Virtual supervision

Extended through 2024

CDS 

Indefinite delay: "Taken together and, in particular, due to the inability of the Medicare claims processing system to automate claims processing edits that ensure only claims subject to the AUC program requirements as prescribed in section 1834(q) of the Act will be processed as such, returned or denied accordingly, we believe the inherent risks in terms of data integrity and accuracy, beneficiary access, and potential beneficiary financial liability for advanced diagnostic imaging services render the AUC program impracticable, and have led us to our proposal to pause efforts to implement the AUC program for reevaluation and rescind current regulations. Working within the parameters prescribed under section 1834(q) of the Act, we have not identified any practical way to move the AUC program forward beyond the educational and operations testing period. Further, without a way forward to fully implement the AUC program, we believe there is no utility in continuing the educational and operations testing period. We will continue efforts to identify a workable implementation approach and will propose to adopt any such approach through subsequent rulemaking. We note, and discuss further below in this section of the proposed rule, that clinical decision support tools can be beneficial in assisting with clinical decision making and we encourage continued use of clinical decision support in a manner that best serves and assists clinicians."

Again, there are proposed cuts to radiology of >10%.  It is also significant that CMS is rescinding the current AUC/CDS regulations. 

The RBMA Federal Affairs Committee will begin a thorough review and draft comments on behalf of the membership.

------------------------------
Robert Still FRBMA
Executive Director
Radiology Business Management Association (RBMA)
Fairfax VA
(703) 621-3363
------------------------------