Today, CMS announced a proposed significant increase -- from 50 to 90 percent-- in utilization rate assumptions used to determine medical imaging reimbursement. The higher the utilization, the lower the agency can set its reimbursement.

"The current payment rates assume that a physician who owns this type of equipment will use it about 50 percent of the time, but recent survey data suggest this expensive equipment is being used more frequently. As the use of this type of equipment increases, the per-treatment costs for purchasing, maintaining and operating the expensive equipment declines, making a reduction in payment appropriate," CMS stated in a press release (see DM 9542).

As DOTmed has previously reported (DM 9494), the suggested change in the Medicare Utilization Rate for imaging has caused much concern in the imaging industry and among practitioners. DOTmed spoke with Cynthia R. Moran, the American College of Radiology (ACR) Assistant Executive Director, about why organizations such as ACR are urging Congress to consider carefully the effect of the proposed rate change.

DOTmed asked Ms. Moran why ACR believed that the proposed change in the rate is based on inaccurate information. Moran explained that the information from the Medicare Payment Advisory Commission (MedPAC) surveys is inaccurate because it did not involve a comprehensive study of equipment utilization. All studies up to this point have involved a very small number of imaging centers or offices interviewed. However, the utilization rate involves many complex issues and, Moran says, a time-intensive effort for physicians and their staff to figure out exactly how often imaging equipment is used.

There have been attempts to capture the data, but these attempts have not included multiple sites and rural areas and the responses have always been very small in number. So to target imaging providers based on that information does not seem just.

"We agree this is a fair policy objective to come up with a rational number on how often medical equipment is used. But we would argue that there is an equipment component in every code in the fee schedule. Every physician uses medical equipment, and if you are going to develop policy, in all fairness you should not single out performers such as imagers and put them under scrutiny with no supporting data simply because we are an easy target," Moran says.

"The utilization of imaging has flattened out over the last few years. It may even be going down in future years. There is no real justification for cherry-picking a policy parameter. If policy makers think the policy needs to change, it should be applied across the board to all services, not just diagnostic imaging."

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