ACloserLook Reimbursement Issues in Diagnostic Imaging

Hospital Outpatient Prospective Payment System (HOPPS)

On July 3, 2008, the Centers for Medicare and Medicaid Services (CMS) issued the 2009 proposed HOPPS rule on their website. The proposed rule provides a 3.0 % increase overall in Medicare payments to hospitals. The final rule will be published in November of this year. The rule will be implemented on January 1, 2009.

Key provisions of the proposed rule include:

Payment for Drugs and Pharmacy Overhead in the HOPPS Setting

CMS is proposing to pay for separately payable drugs and biologicals based on hospitals’ reported costs at the average sales price (ASP) + 4 %. CMS is also proposing to modify the Medicare cost report to establish two cost centers for reporting drugs with high and low pharmacy overhead costs. This would allow CMS to estimate drug and pharmacy overhead costs more accurately in future rate setting.

Payment for Therapeutic Radiopharmaceuticals in the HOPPS Setting

CMS is proposing to provide payment for separately payable therapeutic radiopharmaceuticals ($60 and above) based on ASP data voluntarily submitted by manufacturers through the existing ASP process. The payment rate would be ASP + 4%. If ASP information is not available, CMS is proposing that payment would be based upon mean costs from hospital claims data. Please note that legislation pending at this writing may extend the 2008 payment methodology through 2009.

Payment for Nuclear Medicine Procedures

CMS is proposing to set the payment rates for nuclear medicine procedures based on the established rate setting methodology using claims from 2007 that include a charge for a required diagnostic radiopharmaceutical or other radioactive product. (Hospitals were not required to include radiopharmaceuticals on nuclear medicine claim forms until 2008.) Using claims with the radiopharmaceuticals will derive more appropriate payment rates.

Composite APCs for Multiple Imaging Services

CMS is proposing to establish five imaging composite Ambulatory Payment Categories (APCs) based on the families of codes used in the Medicare Physician Fee Schedule (MPFS) for the multiple imaging procedure payment reduction policy under that system. These composite APCs, which would provide a single APC payment when two or more imaging procedures using the same imaging modality were provided in a single session, would encourage imaging efficiencies under the OPPS. The proposed new imaging composite APCs include:

  • Ultrasound
  • Computed tomography (CT) and computed tomographic angiography (CTA) without contrast;
  • CT and CTA with contrast;
  • Magnetic resonance imaging (MRI) and magnetic resonance angiography (MRA) without contrast; and
  • MRI and MRA with contrast.

The proposed rule continues bundling payments of all diagnostic radiopharmaceuticals and contrast agents with the associated nuclear medicine APC, and will continue paying separately for drugs, biologicals and therapeutic radiopharmaceuticals with a cost of $60 or more per day.
For more information about the proposed OPPS rule, please visit http://www.cms.hhs.gov/HospitalOutpatientPPS/HORD/list.asp#TopOfPage

 

Summer 2008 Newsletter


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