The past few years have been tumultuous for diagnostic imaging, and last year was no different. The industry went on the defensive to protect patient access to quality health care and to shield its Medicare reimbursements from being slashed any further.
The Association for Quality Imaging reacted quickly and effectively to fortify its message and unite its partners to stave off payment reductions. Due to our strong advocacy and deep grassroots network, our members successfully remained untouched by Congress in committee negotiations and recently-passed legislation:
- The President’s FY 2012 and FY2013 Budget proposed to increase the utilization factor for advanced diagnostic imaging services (ADIS) and to impose prior authorization, even though the latter change had no budgetary impact. These cuts still remain viable threats to our industry.
- The Middle Class Tax Relief and Job Creation Act of 2012 (H.R. 3630), introduced by Rep. Dave Camp (R-MI-4), extends through all of 2012 the freeze in the physician payment update, the sustainable growth rate (SGR) fix, made for the first two months of 2012.
- In the Trade Adjustment Assistance (TAA) Extension Act of 2011 (H.R. 2832), also introduced by Rep. Camp, cuts to diagnostic imaging were averted since Congress did not use the industry as a pay-for for the bill.
- Imaging was also on the table for cuts during the U.S. Joint Select Committee on Deficit Reduction negotiations. This “Supercommittee” was formed by the Budget Control Act of 2011 to prevent the sovereign default that could have resulted from the 2011 U.S. debt-ceiling crisis. This bipartisan, bicameral committee could not reach agreement and disbanded.
AQI lobbied to abolish the Independent Payment Advisory Board (IPAB) which was established in the Patient Protection and Affordable Care Act of 2010. This group and has the authority to make changes to the Medicare program without the approval of Congress. IPAB was repealed in March by the U.S. House of Representatives in the Protecting Access to Healthcare Act of 2012 (H.R. 5).
AQI advocated for Congress to eliminate the proposed 50% cut to the professional component (PC) of the Multiple Procedure Payment Reduction (MPPR) for ADIS performed in the same session regardless of modality and family. It was originally proposed at a 50% reduction in the Physician Fee Schedule proposed rule from CMS and was reduced to 25% in the final rule. We continue to advocate for the Diagnostic Imaging Services Access Protection Act of 2011 (H.R. 3269) which would repeal the entire cut.
AQI advocated for the Integrity in Medicare Advanced Diagnostic Imaging Act of 2011 (H.R. 1476), introduced by Congresswoman Jackie Speier (D-CA-12). This legislation excludes certain ADIS from the in-office ancillary services exception to the prohibition on physician self-referral. AQI continues to work with Rep. Speier to champion diagnostic imaging and preserve quality services for Medicare beneficiaries.
AQI worked extensively with the Alliance for Integrity in Medicare (AIM) to obtain a Congressional Budget Office (CBO) score on its self-referral legislation and to have the legislation introduced in debt-ceiling negotiations. We are currently awaiting the score.
AQI promoted Clinical Decision Support (CDS) legislation before Committee staff. This bill promotes utilizing a systematic and clinically-based computerized program to determine the appropriateness of imaging tests over using an unprofessional and ineffective, non-clinical Radiology Benefit Manager (RBM) to deter excessive imaging and unnecessary scans. RBM’s have been a continued threat in multiple vehicles and we will continue to advocate for a better solution to utilization management.
AQI commented to the Centers for Medicare & Medicaid Services on the FY 2011 Proposed and Final Medicare Physician Fee Schedule (MPFS) and Hospital Outpatient Physician Payment System (HOPPS) Rules about recent payment policy updates. Specifically, AQI argued against combined reimbursement codes and a proposed reduction in the conversion factor.
AQI wrote to CMS about utilizing RBMs to develop imaging efficiency measures for the Hospital Outpatient Quality Data Reporting Program. We disputed the idea that RBMs should create these measures with CMS as this policy establishes an unmanageable conflict of interest.
AQI wrote to CMS contesting its recent suspension on the CMS 855B enrollment application for the requirement for ADIS providers to update their Medicare Enrollment Application to document their intention to perform and bill for ADIS provided to Medicare beneficiaries by identifying the ADIS computed procedural terminology (CPT) codes they intended to perform and bill. AQI contends that it is reasonable and appropriate for all non-hospital providers of ADIS to meet the minimal enrollment requirements originally set out by CMS relative to the enrollment of ADIS procedure codes that will be performed and billed prior to being reimbursed for those procedures.
AQI’s Executive Director, Maggie Sayre, addressed audiences of the Radiology Business Management Association (RBMA), the American Healthcare Radiology Administrators (AHRA), and the International Association of Medical Equipment Remanufacturers and Servicers (IAMERS) to educate radiology professionals and imaging vendors about AQI’s initiatives in order to build momentum for a strong and active grassroots network. AQI continues to collaborate with these groups, the Access to Medical Imaging Coalition (AMIC), and the Imaging e-Ordering Coalition (IEOC) to expand AQI’s reach.