ACloserLook Reimbursement Issues in Diagnostic Imaging

2007 Final Rule for the Hospital Outpatient Prospective Payment System (HOPPS)

The Centers for Medicare and Medicaid Services (CMS) published the 2007 final HOPPS rule on their website on November 1, 2006.  The rule is expected to be published in the Federal Register on November 24. The final rule will result in an overall average increase of 3.0 in Medicare payments to hospitals. Provisions described below in this newsletter will be implemented January 1, 2007:

Payment for Contrast Agents

For 2006, CMS used average sales price (ASP) + 6% as a proxy for average acquisition cost. For 2007, CMS proposed to use ASP + 5% for the payment of separately payable drugs other than radiopharmaceuticals.  GE Healthcare urged CMS to maintain separate payment for contrast agents at ASP + 6%.  CMS accepted this recommendation and will continue to pay ASP + 6%.  Hospitals should report contrast on their claim forms using the Q code series Q9945-Q9957.
The final rule indicates that High Osmolar Contrast Media (HOCM) codes Q9958-Q9964 have status indicator “N”, which means the contrast agents are packaged into the payment for the procedure.  Separate payment is not available.

Radiopharmaceutical Payment in the HOPPS Setting

For 2006, CMS adopted a temporary 1 year policy for the payment of radiopharmaceuticals that was based on a hospital’s charges for each radiopharmaceutical adjusted to cost (CCR). CMS encouraged hospitals to adjust their charges to reflect the price paid for the radiopharmaceutical as well as the associated handling cost for the product. 

For 2007, CMS proposed to pay for separately payable radiopharmaceuticals using means costs derived from the CY 2005 claims data.  However, the data did not reflect changes that CMS instructed hospitals to make for 2006 and many of the claims for nuclear medicine procedures did not contain a code for a radiopharmaceutical.  The result was that the proposed payment amounts produced significant variations from current payment levels. 

GE Healthcare, other manufacturers, various medical professional societies, and the APC Advisory Panel urged CMS to continue to use CCR for one more year.  CMS has adopted this recommendation and invites interested parties to suggest alternative payment methodologies for 2008.  

In order to assure proper payment for separately payable drugs, hospitals should verify that their charge masters are current and that coding for nuclear medicine procedures and radiopharmaceuticals is accurate. 

Multiple Diagnostic Imaging Procedure Payment Reduction

Last year, CMS proposed to reduce payment by 50% for certain multiple diagnostic imaging procedures within a “family” of procedures including ultrasound, CT, CTA, MRI, and MRA modalities.  Ultimately, they declined to do so for 2006 and have once again decided not to adopt the reduction for hospital outpatient multiple imaging procedures for 2007.   

Threshold for Separately Payable Outpatient Drugs

CMS will continue the $50 threshold for determining separately payable outpatient drugs. They plan to adjust the threshold annually using the Producer Price Index.  The amount proposed and adopted for 2007 is $55.
For more information about the HOPPS final rule visit:

http://www.cms.hhs.gov/HospitalOutpatientPPS/
Downloads/
CMS1506FC.pdf.

 

Special Edition Fall 2006