The American College of Cardiology (ACC) opposes several of the recommendations related to diagnostic imaging that were included in MedPAC's June 2011 report to Congress.
Among the recommendations:
1. The Secretary should accelerate and expand efforts to package discrete services in the physician fee schedule into larger units for payment.
2. The Congress should direct the Secretary to apply a multiple procedure payment reduction to the professional component of diagnostic imaging services provided by the same practitioner in the same session.
3. The Congress should direct the Secretary to reduce the physician work component of imaging and other diagnostic tests that are ordered and performed by the same practitioner.
4. The Congress should direct the Secretary to establish a prior authorization program for practitioners who order substantially more advanced diagnostic imaging services than their peers.
In particular, the ACC strongly opposes prior authorization of advanced imaging procedures, as the report recommends, because requiring prior authorization would increase the administrative burden on Medicare, increase physician practice costs and could interfere with the physician-patient relationship, potentially delaying timely access to life-saving procedures.”
According to ACC CEO Jack Lewin, MD, this recommendation is likely based on a misconception that Medicare’s imaging costs continue to rise at a rapid rate, while laws and regulations adopted in the last five years have significantly reduce the growth and will continue to impact imaging costs and trends.
The adoption of decision-support tools based on appropriate use criteria is a better option than prior authorization.
The Coalition for Patient-Centered Imaging (CPCI), which represents physician and other health care provider organizations dedicated to high quality imaging, also released a press statement expressing extreme disappointment in the report and noting concerns that the recommendations, if implemented, would undermine efforts to promote the delivery of integrated, patient-centered care that could improve outcomes and help curb rising health care costs.
Over the years, legislative and regulatory changes have led to significant cuts in Medicare payments for advanced imaging and other diagnostic imaging procedures. While the MedPAC report attempts to justify additional cuts by pointing to “rapid volume growth” of 6.3 percent per year in the volume of these services per fee-for-service Medicare beneficiary, it ignores the fact that the volume of imaging services provided outside the hospital began trending downward in 2007, and in 2010 volume for both standard and advanced imaging services per fee-for-service beneficiary actually fell below the 2009 levels. The CPCI letter notes that advanced imaging services also are shifting out of physician offices and into more expensive hospital outpatient departments, suggesting that another round of imaging cuts is not only unnecessary, but would also be counter-productive to efforts to integrate the delivery of care and to address the impact of rising costs on our nation’s health care system and our country’s deficit.