ASNR Advocacy Activities

ASNR Signs-On to Supporting Medicare Providers Act of 2022

Posted on: Oct 10 2022

ASNR signs-on multi-society letter supporting H.R. 8800: Supporting Medicare Providers Act of 2022. The letter is addressed to representatives Bera and Bucshon who introduced the bill.

This legislation would mitigate pending Medicare physician payment cuts by providing a 4.42 percent positive adjustment to the Medicare Physician Fee Schedule (MPFS) conversion factor (CF) for CY 2023. The bill also includes a “Sense of Congress” on the need for legislative and administrative changes to the MPFS to ensure stability, promote and reward value-based care and advance health equity and reduce disparities. Read the full letter here.

ASNR Signs-On to Letter Regarding FY23 Appropriations

Posted on: Sep 26 2022

ASNR signs-on multi-society letter urging congressional leadership to complete the FY23 appropriations by Sept. 30, 2022 at the latest in order to meet research funding needs. Read the letter here.

ASNR Signs-On to Letter Addressed to Congressional Leadership

Posted on: Sep 26 2022

ASNR signs-on AMA drafted multi-society letter addressed to congressional leadership that advocates for financial stability in Medicare physician payment policies. Read the full letter here.

ASNR Signs-On to Letter Regarding Facet Joint Interventions

Posted on: Sep 19 2022

ASNR signs-on multi-society letter to CMS regarding prior authorization for facet joint interventions. The letter advocates against prior authorization. Read the letter here.

ASNR Submits Letter in Support of Henry Woo, MD, Nomination

Posted on: Sep 12 2022

ASNR submits letter in support of the nomination for Henry Woo, MD, Congress of Neurological Surgeons (CNS) CPT Advisor, for the open surgical specialty advisor seat on the CPT Assistant Editorial Board. Read the letter here.

ASNR Signs-On Letter Regarding PPI Survey Recommendations

Posted on: Sep 12 2022

ASNR signs-on multi-society letter addressed to CMS in regard to PPI survey recommendations. CMS currently utilizes data from the AMA’s Physician Practice Information (PPI) Survey in determining Practice Expense relative values. This survey was last conducted in 2007-2008.  Read the letter here.

CY 2023 Physician Fee Schedule Letter Submitted

Posted on: Sep 12 2022

ASNR has submitted a comment letter in response to the CY 2023 Physician Fee Schedule. Read the letter here.

ASNR Signs-On to UHC Letter

Posted on: Aug 12 2022

ASNR signs-on letter to UHC due to the carrier denying RFA procedures above C3-4. The current UHC Coverage Policy limits coverage for injection and radiofrequency ablation of facets at C3-4 and below. The C2-3 facet joint is a common cause of pain and is just as amenable to treatment as the joints from C3-4 and below 7-9. The letter encourages UHC to modify their policy to allow coverage to include joints including C2-3 and below. Read the letter here.

ASNR Signs Joint Statement Regarding Upcoming Hearing in Kelley v. Becerra

Posted on: Aug 1 2022

ASNR signs joint-statement bringing attention to the upcoming hearing in Kelley v. Becerra. An adverse decision would mean that millions of privately insured patients will lose first-dollar coverage for important screening and preventive services, including those approved by the U.S. Preventive Services Task Force, CDC’s Advisory Committee on Immunization Practices, and HRSA’s preventive care and screening guidelines for women, infants, children, and adolescents. Although the impact would be enormous, the importance of this case seems to have been lost with so many other high-profile health issues dominating the media. Read more here: https://www.ama-assn.org/press-center/press-releases/physicians-sound-alarm-lawsuit-threatening-preventive-care

ASNR Signs On the Conversion Factor (CF) Coalition Letter

Posted on: Aug 1 2022

ASNR signs on the Conversion Factor (CF) Coalition letter addressing the recent proposed rule. The MPFS proposed rule revealed a -1.55% RVU BN adjustment to the CF, which combined with the expiration of the 3% positive adjustment from Congress results in an approximately -4.5% reduction to the CF for CY2023. The expiration of delayed statutory PAYGO requirements adds another -4%, which means the entire physician and non-physician provider community is facing (at a minimum) an approximate 8.5% reduction on 1/1/2023. Read the full letter.

ASNR Signs-On to “Long-COVID” Letter

Posted on: Jul 25 2022

ASNR signs-on letter urging Congress to be more active in enhancing our understanding and ensuring adequate resources for “Long COVID,” i.e., post-acute sequelae of SARS-CoV-2 infection (PASC). While there are many unknowns with PASC, it is clear that a sizable number of the population is being impacted by this condition. Providing a national spotlight on this issue will help continue the national dialogue with leading experts, ensure that progress is being made on key priorities, and identify areas for continued federal investment. Read the letter here.

ASNR Signs-On to AMA Drafted Letter

Posted on: May 30 2022

ASNR signs-on AMA drafted letter that details Characteristics of a Rational Medicare Physician Payment System. Developed in collaboration with Federation organizations, this set of principles provides a framework for payment reform as an early step in the effort to develop consensus across medicine on policy recommendations that will reshape the payment system so that it works better for patients and physicians, and put an end to the annual advocacy exercise of stopping impending payment cuts. Work continues on further developing concrete proposals to meet the goals set forth in this document. Read the letter here.

ASNR Signs On to Multi-Society Letter Drafted by SIS

Posted on: May 23 2022

ASNR signs on multi-society letter drafted by SIS to address a proposed bill (Louisiana HB 941) being considered in the State of Louisiana that would restrict the practice of minimally invasive fusion procedures to spine surgeons. The original bill stated that “No physician shall perform a decompression, fusion, or instrumentation procedure on the lumbar, thoracic, or cervical spine unless he has completed a residency in orthopedic surgery or neurosurgery.” The amended version of this bill now addresses fusion only. The letter was submitted to the Louisiana State House of Representatives’ Health and Welfare Committee and bill sponsor, Representative Illg. Representative Illg requested that the bill voluntarily be deferred to allow for additional study of the issues. The Health and Welfare Committee voted to voluntarily defer. We will continue to monitor the bill. Read the letter here.

ASNR Signs On to Ad Hoc Group for Medical Research Letter

Posted on: May 23 2022

ASNR signs on letter drafted by the Ad Hoc Group for Medical Research that recommends a program level of at least $49.048 billion for the NIH base budget, which would represent an increase of $4.1 billion over the comparable FY 2022 funding level (an increase of $3.5 billion or 7.9% in the NIH appropriation plus funding from the 21st Century Cures Act for specific initiatives). Importantly, the Ad Hoc Group strongly urges lawmakers to ensure that any funding for the new Advanced Research Projects Agency for Health (ARPA-H) supplement our $49 billion recommendation for NIH’s base budget, rather than supplant the essential foundational investment in the NIH. Read the letter here.

ASNR Signs-On to Letter to Support Advancement of the FIND Act

Posted on: May 2 2022

ASNR signs-on letter to support the advancement of the Facilitating Innovative Nuclear Diagnostics (FIND) Act of 2021 (H.R. 4479). The letter requests that the Ways and Means and Energy and Commerce leadership hold a hearing to consider the FIND Act and explore the potential of this policy to expand beneficiary access to care, improve health outcomes, create healthcare savings and promote innovation and development in this space. Read the letter here.

ASNR Signs MPW Drafted Letter

Posted on: Apr 13 2022

ASNR signs MPW drafted letter in support of the use of ISD in the treatment of appropriately selected patients suffering from lumbar spinal stenosis. The letter was sent to several Medicare Advantage health plans regarding coverage of interspinous spacer devices. Read the letter here.

ASNR Signs-On to Letters Addressed to the Medicare Administrative Contractors

Posted on: Mar 16 2022

ASNR signs-on letters addressed to the Medicare Administrative Contractors (MACs) presenting evidence and recommendations in advance of the upcoming Multi-jurisdictional Contractor Advisory Committee (CAC) meeting regarding sacroiliac joint interventions. Please read the letter sent to Novitas here. Similar letters were sent to all the MACs.

Multi-Society Appropriations Letter

Posted on: Feb 11 2022

ASNR signs on multi-society letter urging Congress to finalize FY22 appropriations & avoid a long-term continuing resolution. Read the letter here.

ASNR Signs On to Letter Regarding Non-Coverage of DRG-S

Posted on: Jan 24 2022

ASNR recently signed-on a multi-society letter to United Healthcare regarding non-coverage of dorsal root ganglion stimulation (DRG-S). The letter urged UHC to overturn the lack of coverage for this procedure as the need for neuromodulation treatments are essential.

After hearing our concerns and feedback, we are delighted to announce that starting in March 2022, UHC will implement changes to the coverage of dorsal root ganglion (DRG-S) stimulation. Please click here for the updated policy.

ASNR Signs On to AMA Drafted Letter to CMS

Posted on: Dec 20 2021

ASNR signs-on AMA drafted letter to CMS to express strong concerns over unfair business practices with respect to electronic payments in health care. The letter requests that the Biden
Administration swiftly addresses this problem by (a) issuing guidance that affirms physicians’ right to choose and receive basic EFT payments without paying for additional services and (b) undertaking the associated enforcement activities. Read the full letter.

ASNR Signs On to Letter to United Healthcare

Posted on: Dec 13 2021

ASNR signed on ASA/MPW letter to United Healthcare (UHC) regarding the August 2021 non-coverage policy of two important procedures, PNS & DRG-S. UHC deems neuromodulation treatments that include dorsal root ganglion stimulation (DRG-S) and percutaneous peripheral nerve stimulation (PNS) as “not medically necessary,”. Both of these treatments have evidence of efficacy despite what the United Healthcare Policy states. Read the full letter.

ASNR Signs On to Letter Urging Removal of Certain NCCI PTP Edits

Posted on: Dec 7 2021

ASNR signs-on multi-society letter from The American College of Radiology, American College of Cardiology, American Roentgen Ray Society, American Society of Neuroradiology, Association of University Radiologists, Radiology Society of North America, Society of Cardiovascular Computed Tomography, and the Society of Interventional Radiology strongly urging the removal of the National Correct Coding Initiative(NCCI) Procedure to Procedure (PTP) edits between HCPCS codes 75574 (Coronary Computed Tomography Angiography-CCTA) and 0623T, 0624T, 0625T and 0626T0 (Atherosclerosis Imaging Quantitative Computed Tomography [AI-QCT]). The rationale for the edits given in the current PTP files are that these are, “mutually exclusive procedures,” but the service provided by 0623T-0626T is separate and distinct from the service of 75574. Read the full letter.

ASNR Signs on to Letter Urging Congress to Extend the MPFS

Posted on: Dec 6 2021

ASNR signs-on multi-society letter to Speaker Pelosi and Leaders Schumer, McConnell, and McCarthy urging congress to extend the 3.75% payment adjustment through at least CY 2022. Congress’ commitment to ensuring greater stability within the Medicare Physician Fee Schedule (MPFS) for calendar year (CY) 2021, via a 3.75% payment adjustment for all services, avoided significant disruptions to care for Medicare beneficiaries and provided a lifeline for health care providers as the COVID-19 pandemic continues to stress the healthcare delivery system. Unfortunately, this temporary measure did not address the ongoing structural problems with the MPFS, and the provider community is again bracing for steep cuts in 2022, which could result in many beneficiaries losing timely access to essential health care services. Read the full letter.

ASNR Signs On to Letter to the Departments of Health and Human Services, Treasury and Labor

Posted on: Nov 22 2021

ASNR signs-on AMA drafted letter to the Departments of Health and Human Services, Treasury and Labor (the Departments) asking that they revise requirements in the most recent Interim Final Rule (IFR) implementing the No Surprises Act (NSA) that require an Independent Dispute Resolution (IDR) entity to assume the Qualified Payment Amount (QPA) is a reasonable out-of-network rate, unless credible information submitted by the parties clearly demonstrates that the QPA is materially different from the appropriate out-of-network rate. Read the letter here.

ASNR Signs On to Medical Research Letter to Congress

Posted on: Nov 19 2021

ASNR signs-on Ad Hoc Group for Medical Research letter to Congress urging swift passage of FY22 spending bills, including $46.4 billion for the NIH. Read the letter here.

CMS Releases Final Rule for the CY 2022 Medicare Physician Fee Schedule

Posted on: Nov 15 2021

The Centers for Medicare & Medicaid Services (CMS) released the final rule for the CY 2022 Medicare physician fee schedule. The ASNR Health Policy team is currently in review of the document but would like to share our initial conclusions. The 2022 Medicare conversion factor will be reduced by approximately 3.85% from 34.8931 (2021) to 33.5983. The significant reduction is a result of the expiration of a 3.75% increase to the conversion factor at the end of calendar year 2021, as averted in 2021 by Congressional action. It is important to note that there still may be congressional action that takes place to alleviate the reduction by extending the 3.75% increase for 2022.

Final Rule: https://www.federalregister.gov/public-inspection/2021-23972/medicare-program-cy-2022-payment-policies-under-the-physician-fee-schedule-and-other-changes-to-part

Anticipated Final Clinical Labor Pricing Effect on Specialty Impacts:
Radiology: Allowed Charges (mil): $4,417 New CL Pricing Change -1%

AUC Program:
After consideration of public comments, the proposal is finalized to begin the payment penalty phase of the AUC program on the later of January 1, 2023, or the January 1 that follows the declared end of the PHE for COVID-19​.

Physician-self referral:
As described in section III.P.1. of this final rule, unless an exception applies and its requirements are satisfied, the physician self-referral law prohibits a physician from making a referral for the furnishing of certain designated health services if the physician has a financial relationship with the entity to which the referral is made. Section 1877(h)(6) of the Act and §411.351 of the regulations specify that Radiology and certain other imaging services are defined as designated health services.

CY 2022 PFS Estimated Impact on Total Allowed Charges by Specialty:
Radiology:

Allowed Charges (mil): $4,257
Impact of work RVU Changes: 0%
Impact of PE RVU Changes:-1%
Impact of MP RVU Changes: 0%
Combined Impact:-1%

LCD and Other Documents Sent Out Regarding the Epidural Steroid Injections for Pain Management

Posted on: Oct 29 2021

On behalf of all the Medicare Administrative Contractors (MACs), the attached LCD and other appropriate documents (Epidural BC; RTC Epidural) were sent out regarding the Epidural Steroid Injections for Pain Management Policy, effective December 5, 2021. This policy was developed and adopted by all the MACs, except Noridian.

CGS Administrators (J15) will be hosting an educational webinar, on November 12, 2021, and if you have specific questions you wish to have addressed during the webinar, please send them to J15MRPOLICY@cgsadmin.com by 11/8/21.

Registration is available at: https://cgsmedicare.com/medicare_dynamic/wrkshp/pr/partb_report/partb_report.aspx.

ASNR Signs-On to AMA Drafted Letter to the CMS National Standards Group

ASNR signs-on AMA drafted letter to the Centers for Medicare & Medicaid Services (CMS) National Standards Group to clarify and enforce the right of physicians to receive electronic payments via the Automated Clearing House electronic funds transfer (EFT) standard without being forced to pay percentage-based fees for “value-added” services. Read the full letter.

ASNR Supports the AANS/CNS Nomination of Joseph Cheng, MD, for the CPT Editorial Panel

Posted on: Oct 11 2021

The undersigned organizations are pleased to support Joseph S. Cheng, MD, for a position on the AMA CPT Editorial Panel. Nominated by the American Association of Neurological Surgeons (AANS) and the Congress of Neurological Surgeons (CNS), Dr. Cheng would be an excellent addition to the panel. Read the full letter.

ASNR Comments on Medicare Program

Posted on: Sep 20 2021

CY 2022 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B to Payment Policies; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program Requirements for Eligible Professionals; Payment for Office/Outpatient Evaluation and Management Services; Proposed Rule. Read the full letter.

ASNR Signs On to the AMA Opposition Letter to Develop National Standards of Practice

Posted on: Aug 2 2021

ASNR signs-on the American Medical Association drafted letter opposing the Department of Veterans Affairs (VAs) effort, referred to as the Federal Supremacy Project, to develop National Standards of Practice for 48 healthcare occupations. As the name implies, the VA is invoking the Supremacy Clause of the Constitution to preempt state and local scope of practice laws as it develops National Standards of Practice that could enable nurses, physician assistants, and other non-physicians to provide services and perform procedures that are outside the scope of their knowledge and licensure. The letter also calls into question the feasibility of developing a single National Standard of Practice for all VA-employed physicians. Read the full letter.

ASNR Signs On to Letter Urging Continued Stability of Medicare Physician Fee Schedule

Posted on: Jul 27 2021

ASNR signs-on to a coalition letter highlighting the need for continued stability within the Medicare Physician Fee Schedule. To avoid the proposed steep cuts, the signed-on organizations urge Congress to maintain the 3.75% increase to the Conversion Factor through at least calendar years 2022 and 2023 (Congress ensured greater financial stability in the Medicare program for 2021 by instituting the increase). Read the full letter.

ASNR Signs on to Letter Providing Input on Indirect Physician Expense Data Collection Effort

Posted on: Jul 1 2021

The American College of Radiology, American Society of Neuroradiology, and the Society for Nuclear Medicine & Molecular Imaging sent a letter to the RAND Corporation providing input on the indirect Physician Expense (PE) data collection effort. The letter specifically provided feedback per the June 16, 2021, CMS Practice Expense Town Hall Meeting regarding Improving Data and Methods Related to the Indirect Practice Expense in the Medicare Physician Payment Schedule that ASNR participated in. Read the full letter.

ASNR Signs On Letter Urging Support for the Medical Research Enterprise

Posted on: May 21 2021

ASNR signs on letter to Congressional leadership urging support for the medical research enterprise in upcoming legislation to strengthen the nation’s infrastructure and bolster economic recovery. View the letter here.

MPW AHRQ Chronic Pain Intervention letter

Posted on: May 17 2021

ASNR/ASSR sign-on MPW drafted letter to the Agency for Healthcare Research Quality (AHRQ) after reviewing and submitting comments regarding the AHRQ published draft systematic review: Interventional Treatments for Acute and Chronic Pain.

Posted on: Apr 27 2021

ASNR signs-on E/M Coalition letter urging Congress and the Administration to make a critical investment in the nation’s health care infrastructure by providing an additional $3 billion for the MPFS to once again mitigate expected reductions to the Medicare conversion factor, ensuring financial stability for physicians and practices in 2022.

Posted on: Apr 1 2021

ASNR participated in the development of the practice advisory on contrast media. It has been published online in Anesthesia & Analgesia.

Posted on: Mar 19 2021

Please see attached for the policy adopted by all participating Medicare Administrative Contractors (MAC) regarding Facet Joint Interventions for Pain Management and other related documents, effective April 25th, 2021. This policy was developed and adopted in a multi-jurisdictional MedCAC indicating it has broad coverage implications. On March 12, 2021, The Medicare Administrative Contractors held a meeting in order to receive feedback and input regarding the policy coverage.

The governing MAC requested that ASNR President, Joshua A. Hirsch, MD, FACR, FSIR, FSNIS serve as a Subject Matter Expert for the panel. He was one of only two radiologists to serve in such a capacity. As a result, ASNR along with other societies were at the table, actively participating in the discussion. To our knowledge, Dr. Hirsch is the only individual who has served as an invited subject matter expert for all three of the multi-jurisdictional MedCACs dealing with interventional pain techniques.

The American Society of Neuroradiology collaborated with other radiology, pain and surgical societies that are involved in the care of these patients. As a result, ASNR was instrumental in understanding the evidence regarding Facet Joint Interventions and thus in the developing the policy. Mellissa Chen, chair of the Economics committee noted that “Dr. Hirsch’s leadership is well known to members of our committee. Whether it is CPT/RUC, standards and guidelines or quality, ASNR is active in supporting the care neuroradiologists provide. The fact that ASNR had a direct seat at the table for all 3 of these recent MedCACs underscores the crucial role ASNR is poised to play in supporting our providers and patients alike.” Dr. Chen continued, “volunteer advisors and staff worked diligently alongside Dr. Hirsch in advocating for coverage, and we are pleased with the outcome of our efforts. Most importantly, the efforts of the society have allowed for extended patient coverage.”

Please feel free to view the details in the documents below. Congratulations to ASNR members and the patients they serve!

A58364_Billing and Coding_Facet Joint Interventions for Pain Management

A58613_Response To Comments_ Facet Joint Intervention for Pain Management

L38773_Facet Joint Interventions for Pain Management

Posted on: Mar 12 2021

ASNR participated in a multi-society effort and endorsed the article, “Recommendations for Regional Stroke Destination Plans from the Prehospital Stroke System of Care Consensus Conference”. The article was published in Stroke.

Please see the following links for more information: https://www.ahajournals.org/doi/10.1161/STROKEAHA.120.033228

https://www.aan.com/practice/quality-measures

Posted on: Mar 11 2021

The Academy for Radiology & Biomedical Imaging Research would like to share the following message with ASNR members:

Please tell Congress to Invest in NIH and medical imaging research for FY2022!

NIH continues to be a vital part of supporting research into a wide spectrum of diseases, disorders, and conditions. In the last appropriations bill, Congress lessened its support for NIH as compared to prior years. While the economic stressors of the global pandemic and resulting economic downturn explained this result, NIH funding barely kept pace with the rate of biomedical research inflation.

In FY2022, it is imperative that Congress treat this past year as an anomaly to its previous strong support for NIH. The Academy, along with its partners in biomedical research advocacy, are recommending Congress provide $46.111 billion to NIH, a $3.177 billion increase over FY21. This vital increase will continue to support the role radiology and imaging research play across a wide range of diagnostics, treatments, and therapeutics across NIH research that ultimately benefit patients and their families.

We highly encourage you to “Take Action”. The link below will lead you to a recommended letter and tweet you can send to your elected officials urging them to support NIH and its full range of biomedical research efforts. We encourage you to tell them about your work to improve patient outcomes, encouraging them to invest in the scientific enterprise.

Your advocacy efforts to advance biomedical research funding have resulted in significant victories and increases over the last five years, but without constant effort we risk backsliding to a time when NIH received no funding increases. Contact your members of Congress today and tell them to continue supporting biomedical research and advances in imaging.

Learn More

Posted on: Feb 24 2021

ASNR signs-on E/M Coalition letter stating appreciation to congress for alleviating devastating payment cuts to providers across the health care delivery system that were set to take effect under the 2021 Medicare Physician Fee Schedule (MPFS). The letter also calls attention to the continued critical need for reforms to the Medicare system and additional work required to resolve deficiencies in the MPFS, including addressing the budget neutrality requirement which can lead to arbitrary reductions to reimbursement unrelated to the cost of providing care.

Posted on: Feb 20 2021

ASNR signs on multi-society letter from the Academy’s coalition partner, the Ad Hoc Group for Medical Research, in support of increased NIH funding in FY22.

Epidural Interventions for Chronic Pain Management-Multi-Jurisdictional Contractor Advisory Committee (CAC) Meeting

Posted on: Feb 17 2021

ASNR President, Joshua A. Hirsch, MD, FACR, FSIR, FSNIS participated as a Subject Matter Expert (SME) in the collaborative national evidence review advisory meeting on February 11, 2021. The combined meeting was with all Medicare Administrative Contractors (MACs) regarding developing a collaborative local coverage determination (LCD) addressing the use of epidurals for pain management. The meeting was virtual due to the pandemic and hosted by Novitas and First Coast.  The workgroup evaluated the evidence and will consider the input of the evidence review in the development of a draft LCD. Once that draft is complete, each MAC will post the draft.

Beyond being the only radiologist on today’s panel, to our knowledge, Dr. Hirsch is the only invited SME to be involved in each of the three multi-jurisdictional MedCACs that have occurred since they were conceived as part of the 21^st Century Cures Act. ASNR is grateful for Dr. Hirsch’s expertise and the visibility these efforts bring the specialty.  This MedCAC represents another dimension of ASNR’s role as leaders in the field of medicine. Please see attached for more information on the SMEs that were asked to participate in the meeting. We will continue to monitor any developments.

To learn more about MACs, please see the following link: What is a MAC | CMS

To learn more about LCDs, please the following link: Local Coverage Determinations | CMS

To learn more about Health Policy at ASNR, please see the following link: Health Policy | ASNR

Posted on: Feb 17 2021

ASNR signs-on AMA drafted multi-society letter to congressional leadership advocating that Congress pass legislation to extend the current moratorium on the two percent Medicare payment sequester beyond the March 31 expiration date. Specifically, the letter strongly urges Congress to pass H.R. 315, the “Medicare Sequester COVID Moratorium Act”—bipartisan legislation that would continue the current Medicare sequester moratorium for the duration of the public health emergency.

Posted on: Feb 11 2021

Here is an initial AMA guide to the major provisions in the “No Surprises Act,” the surprise billing legislation that was included in the Consolidated Appropriations Act COVID-19 relief bill signed into law on December 27, 2020. The No Surprises Act allows for price transparency, provider directories, and patient financial protections that impact health plans, physicians, facilities, and other non-MD/DO licensed health care professionals. The law goes into effect on January 1, 2022. The intent of the law is not to preempt state surprise billing laws. However, there is some ambiguity in the statutory language that will require further clarification before and during the rulemaking process, including when the surprise billing protections apply to patients in self-funded ERISA plans. The AMA will work with Federation members and other stakeholders to seek clarification to address these ambiguities and will revise this guide accordingly as new information becomes available.

Authority of VA Professionals to Practice Health Care

Posted on: Jan 8 2021

ASNR sign-on letter that opposes the Department of Veterans Affairs (VA) Interim Final Rule (IFR) , titled “Authority of VA Professionals to Practice Health Care.” The IFR establishes the VA’s authority to allow virtually all non-physician providers, as defined in the U.S. Code (38 U.S.C. 7401(1) or (3)), to practice without the clinical supervision of a physician. In doing so, the IFR preempts state license, registration, certification, supervision or other requirements. The letter also asserts that the IFR is unlawful rulemaking because the VA did not follow the normal notice and commenting process stipulated by the Administrative Procedures Act (APA).

AMA Summary of Select Provisions of the Consolidated Appropriations Act 2021

Posted on: Jan 8 2021

On December 22, 2020, the President signed into law the Consolidated Appropriations Act, 2021, a comprehensive omnibus spending package that funds the federal government through FY 2021, provides a new round of COVID relief and economic stimulus, and imposes new restrictions on surprise medical billing. An AMA summary of select provisions in the bill can be found here. With respect to COVID relief, the legislation would ease the impact of Medicare fee schedule budget neutrality adjustments in calendar year 2021 due to improved evaluation and management (E/M) office visit payment and coding rules, as well as an extension of the 2% Medicare sequester moratorium through March 2021. An AMA analysis estimating the impact of the Medicare payment changes (excluding the sequester moratorium extension) can be found here.

Posted on: Dec 15 2020

ASNR signs-on an E/M Coalition Letter that states support for Sen. Boozman et al. Sen. Boozman introduced a Senate companion bill for HR 8702. The new bill is nearly identical to HR 8702, but includes an updated reference for GPC1X—which is now G2211.

Posted on: Dec 14 2020

ASNR signs-on document drafted by the American Society for Microbiology (ASM) and the American Association for the Advancement of Science (AAAS) to Congressional leadership urging swift action to complete work on the FY 2021 appropriations bills. The document garnered more than 170 organizations and institutions across all disciplines and areas of science and research. The letter sends a strong message about the importance of federal R&D and the need for timely enactment of these bills.

Posted on: Dec 14 2020

Attached is a summary of the Final Rule for the 2021 Medicare Physician Payment Schedule (PFS) and Quality Payment Program (QPP) put together by the American Medical Association Staff.

The Centers for Medicare and Medicaid Services published its Final Rule for the 2021 Medicare Physician Fee Schedule yesterday.  Unfortunately, CMS did not address the drastic cuts associated with the implementation of its 2021 evaluation and management (E/M) policy.  As a result, radiologists, as well as many other health professionals, face Medicare reimbursement reductions of as much as 10%.  The only way to stop these cuts before they are implemented next month is through Congressional legislation.  Since the legislative calendar is quickly waning, you must click on the Call to Action (CTA) link below today to make sure your senators know how important it is for your patients and your practice to stop these cuts before the end of the year.

Thank you in advance for participating in this Call to Action.  You are strongly encouraged to send this email and link to other colleagues so they may participate as well.

Also, please see the following link to view the ASNR summary regarding the (CY) 2021 Medicare Physician Fee Schedule (MPFS) Final Rule: Advocacy Activities | ASNR

Please contact Rahul Bhala, MBA, MPH with any questions or comments at rbhala[at]asnr[dot]org.

Posted on: Dec 3 2020

ASNR signs-on E/M Coalition drafted statement in response to the final rule

(CY) 2021 Medicare Physician Fee Schedule (MPFS) Final Rule

Posted on: Dec 2 2020

On Tuesday, December 1, 2020, the Centers for Medicare & Medicaid Services (CMS) released the 2021 Medicare Physician Payment Schedule Final Rule. The ASNR Economics team continues to analyze the final rule, but has provided the following summary:

Final Rule: https://www.cms.gov/files/document/12120-pfs-final-rule.pdf

The CY 2021 physician payment conversion factor is $32.41.

CY 2021 PFS Estimated Impact on Total Allowed Charges by Specialty:

Interventional Radiology:

Allowed Charges (mil): $499

Impact of work RVU Changes: -3%

Impact of PE RVU Changes: -5%

Impact of MP RVU Changes: 0%

Combined Impact: -8%

Radiology:

Allowed Charges (mil): $5,275

Impact of work RVU Changes: -6%

Impact of PE RVU Changes: -4%

Impact of MP RVU Changes: 0%

Combined Impact: -10%

E/M Services:

E/M Services billed by physicians and some nonphysician providers will result in significant cuts of up to 10 percent or more for certain specialties. Due to Medicare’s budget-neutrality requirements, physician, nonphysician, and institutional providers billing under the PFS will experience substantial payment reductions to offset payment increases to physicians and other providers who primarily deliver office-based services.

By law, significant increases in Medicare physician payment rates must be offset by across-the-board decreases.  ASNR continues to advocate for Congress to include legislation in any year-end package to prevent these arbitrary Medicare cuts and has signed on an E/M Coalitions statement in response to the cuts. YOU can take action by contacting your members of Congress.

X-Ray of Eye (CPT code 70030):

After consideration of the public comments, CMS is finalizing the proposed work RVU of

0.18 as well as the proposed direct PE inputs for CPT code 70030.

CT Head-Brain (CPT codes 70450, 70460, and 70470):

After consideration of the public comments, CMS is finalizing as proposed work RVUs of 0.85, 1.13, and 1.27 for CPT codes 70450, 70460, and 70470 respectively.  As you may recall, a stakeholder nominated CPT code 70450 (Computed tomography, head or brain; without contrast material) as potentially misvalued, citing GAO and MedPAC reports that suggest that work RVUs are overstated for procedures such as these.  After surveying, CMS agreed with our proposed work values (maintain valuation) and finalized in the rule.

Please contact Rahul Bhala at rbhala[at]asnr[dot]org with any questions or comments.

Posted on: Nov 11 2020

The CPT Editorial Panel approved CPT code 99072 to be used to report the additional supplies, materials, and clinical staff time over and above the practice expense(s) included in an office visit or other non-facility service(s) when performed during a public health emergency (PHE), as defined by law, due to respiratory-transmitted infectious disease. To help address the significant fiscal pressures placed on physicians by the COVID-19 pandemic, ASNR signs-on the attached AMA drafted letters urging the Centers for Medicare & Medicaid Services (CMS), America’s Health Insurance Plans (AHIP), Blue Cross Blue Shield Association (BCBSA), and major commercial health plans (i.e., Anthem, Aetna, Cigna, Health Care Service Corporation, Humana and UnitedHealthcare) to immediately implement and pay for CPT code 99072.

Posted on: Nov 11 2020

ASNR signs on E/M coalition letter in support of H.R. 8702. The legislation would stop the Medicare physician payment cuts that are scheduled for January 1, 2021. The letter was delivered to the bill sponsors’ and includes 74 signatories.

ASNR signs-on an EM coalition letter to CMS on the proposed 2021 Medicare physician fee schedule. This letter outlines provider concerns with the EM code proposal in the fee schedule.

Posted on: Oct 5 2020

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ASNR and ASSR sign-on SIS/MPW drafted comment letter addressing CMS’ OPPS proposed requirement for prior authorization for neurostimulation implantation

Posted on: Oct 5 2020

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CY 2020 Medicare Physician Fee Schedule Proposed Rule Letter

Posted on: Oct 7 2020

ASNR submits comment letter to CMS regarding the CY 2020 Medicare Physician Fee Schedule Proposed Rule.

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CPT Advisor Update

ASNR has promoted Colin Segovis, MD to the ASNR CPT primary advisor role. Dr. Segovis worked diligently over the past several years as the alternate advisor and successfully assisted ASNR by making an impact in the CPT process and in achieving our goals. Gaurang Shah, MD, FACR has been appointed as the ASNR alternate CPT advisor. Dr. Shah has attended meetings as a guest of ASNR recently and is familiar with the CPT process. He brings with him many years of experience and expertise, and we are grateful to have him on the team.

ASNR would like to thank Raymond Tu, MD, FACR for his years of commitment and dedication as the primary CPT advisor. Dr. Tu has led ASNR through many complex tabs, issues, and collaborations with several specialty societies. ASNR is considered an essential member of the CPT process because of Dr. Tu’s leadership. As Dr. Tu steps down from the primary advisor role, he will continue to consult and be involved as an integral CPT team member. ASNR is indebted to him for his years of service to the society and the CPT process.

ASNR/ASSR signed-on SIS drafted comment letter to United Healthcare

ASNR/ASSR signed-on SIS drafted comment letter to United Healthcare (UHC) advocating for coverage of lumbar provocation discography as an important tool to assist in the diagnosis of pain refractory to conservative treatment. United Healthcare (UHC), in their most recent coverage policy has classified lumbar provocation discography as unproven or not medically necessary.

NPRM for 2021 Medicare Physician Payment Schedule

Posted on: Aug 3 2020

On August 3, 2020, the Centers for Medicare & Medicaid Services released the Proposed Rule for the Physician Fee Schedule 2021. The Conversion Factor for 2021 is estimated to decrease by 10.61% to $32.2605 as a result of the E/M coding and valuation changes due to budget neutrality issues.

CMS proposed to accept the RUC recommendations on Neuroradiology codes for the X-ray of the eye and CT head. In particular, CMS proposed to maintain the value of the CT head family (CPT codes, 70450, 70460, and 70470) with work RVUS of 0.85, 1.13, and 1.27, respectively.

The ASNR will provide formal feedback to CMS regarding the proposed rule. Please feel free to contact Rahul Bhala at rbhala@asnr.org with any questions or comments.

A fact sheet summarizing the NPRM can be found here.

ASNR signs on AMA drafted letter that strongly urges HHS to utilize its authority under the public health emergency declaration to preserve patient access to care and mitigate financial distress due to the pandemic by implementing the office visit increases as planned while waiving budget neutrality requirements for the new Medicare office visit payment policy.E & M Sign-on letter to HHS Budget Neutrality

ASNR submits letter in regards to support of the INvestigational Kyphoplasty Efficacy and Safety Trial (INKTEST) submission to NIAMS under PAR-20-090 for funding to enable a Clinical Trials Planning Grant focused on Kyphoplasty for treatment of patients suffering from painful, osteoporotic compression fractures.

Sign-On to Coronavirus Provider Protection Act

Attached is a sign-on letter to congressional leadership urging them to include liability protections for physicians in the next COVID-19 relief package, and in particular the protections that are included in the bipartisan bill, H.R. 7059, the “Coronavirus Provider Protection Act,” introduced by Reps. Phil Roe, MD (R-TN) and Lou Correa (D-CA).

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AMA Urges Governors to Adopt Emergency Response Protections for Physicians

Posted on: Apr 23 2020

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ASNR signs-on AMA drafted letter to Congressional leadership requesting additional support for physician practices in the fourth COVID-19 legislative package that is being developed

Posted on: Apr 23 2020

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ASNR signs-on AMA drafted multi-society letter regarding HHS emergency funding

Posted on: Apr 23 2020

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Academy for Radiology & Biomedical Imaging Research letter regarding Phase 3-Emergency Supplemental Funding to Respond to COVID-19 (ASNR is a member of the Academy).

Posted on: Apr 23 2020

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ASNR signs-on AMA drafted letter to Congressional leadership regarding inclusion of support for physician practices in any economic stimulus package.

Posted on: Mar 30 2020

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ASNR/ASSR signs-on letter in response to the vertebral augmentation LCD published by Noridian

Posted on: Mar 30 2020

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Diversity and Inclusion and the ASNR

Posted on: Mar 1 2020

By John E. Jordan MD, MPP, FACR

The American Society of Neuroradiology (ASNR) states on its website that it is “dedicated to maximizing the benefits of neuroradiology to patients and other providers, by promoting the highest standards for training and practice, and fostering research in the field.”  Moreover, the mission statement of the ASNR is to “promote the medical and social well-being of persons with disabling neurologic disorders, to advance training and research in the basic and clinical sciences that can lead to functional recovery of neurologically impaired persons, and to disseminate the knowledge of this research among professionals and the general public.”  The ASNR has evolved into a highly complex and diverse organization since its founding in 1961.  Its activities encompass, but are not limited to: advocacy; clinical standards and guidelines; health policy matters, payment policy and government liaison functions; basic and clinical research, grant funding; a variety of publications including the American Journal of Neuroradiology, Neurographics, social media, and electronic publications; education, including the Annual Meeting and Symposium; subspecialty Society support and management; and the administration of the Foundation of the ASNR.

The ASNR has become more complex in part as the U.S. society has become increasingly diverse and complex.  For example, demographic trends indicate that the major minority populations in the U.S., sometimes collectively referred to as ‘people of color’ (Hispanics, African Americans, Asians, other groups), represented roughly 40% of the population in 2016.  By 2050 that proportion is expected to increase to 54% of the U.S. population. (1)  Furthermore, the world as a whole has become increasingly diverse and interconnected.  In recognition of the growing diversity in the U.S. the ASNR Board of Directors has established a Diversity and Inclusion Task Force to recommend courses of action to the ASNR in order to incorporate diversity and inclusiveness throughout its many programs, functions, and activities.   It is anticipated that this Task Force will evolve into a permanent standing Committee of the ASNR.  Many businesses and organizations have also embraced diversity and inclusion as a strategic imperative.  At a basic level, diversity indicates the ability of an organization or institution to leverage the power of its diverse individuals or diverse elements, while inclusion connotes a cultural branding to welcome and encourage the diverse inputs, creative intelligence, and talents of these individuals.  This in turn can propel an organization to ascendancy and greatness.

An apt analogy of ascendancy and greatness as a result of its diverse elements is the U.S. Olympic team.  As a whole it is unrivaled by any other country, even those more populous than the U.S.  From the gymnasts, to the sprinters, to the swimmers, and alpine participants–it may not dominate in every single endeavor–but in the aggregate, it is unparalleled as a team, and coterminous with its diversity.  Publicly traded companies that truly embrace diversity and inclusion outperform those in financial returns by up to 35% compared with industry means.  When analyzing those companies for gender diversity in leadership, they were 15% more likely to have financial returns above industry means (2,3)

Ultimately, it must be emphasized that the ASNR is an organization dedicated to the advancement of science in its domain and sphere of influence.  And diversity and inclusion efforts recognize that there is no scientific basis for unfounded bias that limits the creative intelligence, innovation, and expressions of any diverse body.  Such biases based on gender or race or ethnicity usually derive from social constructs rather than scientific principles.  Witness that neuroimaging of the brain reveals similar features and radiomics across races, for example, and it is impossible to deduce one’s race or ethnicity from the images alone.  Furthermore, anthropologic sciences have revealed that the diverse human family has descended from a common primal origin.  It is in the spirit of this awareness that the ASNR embraces diversity and inclusion, and encourages all of its members and affiliates to embrace these values as well, further augmenting the house of neuroradiology value chain. (4)

References

1. S. Census Bureau, 2017 National Population Projections, Projections of Race and Hispanic Origin, 2017-2050.
2. Hunt, V., Layton, D., Prince, S. Diversity Matters. February 2015. McKinsey & Company Report. Available at: https://www.mckinsey.com/~/media/mckinsey/business%20functions/organization/our%20insights/why%20diversity%20matters/diversity%20matters.ashx  [Accessed February 21, 2020].
3. Rock, D., Grant, H. (2016). Why Diverse Teams are Smarter.  HBS No. H038YZ. Boston, MA: Harvard Business School Publishing.
4. Lightfoote JB, Fielding JR, Deville C, et al. Improving diversity, inclusion, and representation in radiology and radiation oncology part 1: why these matter. J Am Coll Radiol. 2014;11(7):673–680. doi:10.1016/j.jacr.2014.03.007

ASNR signs multi-society letter of support for an increase to NIH funding

Posted on: Feb 10 2020

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FDA Communication: MicroVention Woven EndoBridge (WEB) Aneurysm Embolization System: Update on Product Performance and Reported Adverse Events

Posted on: Jan 31 2020

Dear ASNR Members,

ASNR was recently contacted by the Food and Drug Administration (FDA), Center for Devices and Radiological Health (CDRH), Office of Product Evaluation and Quality (OPEQ), Office of Neurological and Physical Medicine Devices (OHT5) about ongoing post-market surveillance regarding the MicroVention Woven EndoBridge (WEB) Aneurysm Embolization System.

On December 18, 2019 MicroVention released a letter to healthcare providers to provide an update on product performance and reported adverse events and to advise healthcare practitioners on best practices. Specifically, 6 intra-procedural, intracranial aneurysm ruptures caused by aneurysm wall perforation were reported to MicroVention in 2019 that resulted in patient deaths due to iatrogenic intra-procedural subarachnoid hemorrhage – 4 in the US and 2 outside of the US. Please see the attached letter for additional details.

User facilities should report device-related deaths and serious injuries to MicroVention (the manufacturer), at fieldassurance@microvention.com.  Device-related deaths should also be reported to the FDA.  Voluntary reports can be submitted through MedWatch, the FDA Safety Information and Adverse Event Reporting program (https://www.fda.gov/safety/medwatch-fda-safety-information-and-adverse-event-reporting-program/reporting-serious-problems-fda).

We request that members follow the attached guidance and report any adverse events.  Please feel free to reach out to us with any questions or comments.

Best,

Robert M. Barr, MD, FACR
Mecklenburg Radiology Associates, P.A.’
Charlotte, North Carolina
rbarr@meckrad.com
704-384-3646 (work)

American Society of Neuroradiology (ASNR)
President 2019-2020

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ASNR and ASSR sign on Multi-Society Pain Workgroup letters to Novitas and First Coast regarding their proposed Local Coverage Determinations for Percutaneous Vertebral Augmentation for Vertebral Compression Fractures, DL35130 and DL34976, respectively.

Posted on: Jan 28 2020

Please see attached for the letters.

• 2020 MPW-First Coast LCD-PVA for VCF

The MIPS 2019 Data Submission Period is Now Open / Check Your Initial 2020 MIPS Eligibility on the QPP Website

Posted on: Jan 3 2020

The MIPS 2019 Data Submission Period is Now Open

MIPS Eligible Clinicians Can Start Submitting Data for 2019 through March 31

The Centers for Medicare & Medicaid Services (CMS) has opened the data submission period for Merit-based Incentive Payment System (MIPS) eligible clinicians who participated in the 2019 performance period of the Quality Payment Program. Data can be submitted and updated from 10:00 a.m. EST on January 2, 2020 until 8:00 p.m. EDT on March 31, 2020.

Please note, the data submission period through the CMS Web Interface for ACOs and pre-registered groups and virtual groups also opens on January 2, 2020 and closes on March 31, 2020. Quality measures reported via Medicare Part B claims have been submitted throughout the 2019 performance period. Sign in to qpp.cms.gov for your preliminary feedback on Part B claims measure data processed to date. We’ll update this feedback at the end of the submission period with claims processed by your Medicare Administrative Contractor within the 60 day run out period.

How to Submit Your 2019 MIPS Data

Clinicians will follow the steps outlined below to submit their data:

1. Go to the Quality Payment Program website
2. Sign in using your QPP access credentials (see below for directions)
3. Submit your MIPS data for the 2019 performance period or review the data reported on your behalf by a third party.

How to Sign In to the Quality Payment Program Data Submission System

To sign in and submit data, clinicians will need to register in the HCQIS Authorization Roles and Profile (HARP) system. For clinicians who need help enrolling with HARP, please refer to the QPP Access User Guide.

Note: Clinicians who are not sure if they are eligible to participate in the Quality Payment Program can check their final eligibility status using the QPP Participation Status Lookup Tool. Clinicians and groups that are opt-in eligible will need to make an election before they can submit data. (No election is required for those who don’t want to participate in MIPS.)

Small, Underserved, and Rural Practice Support

Clinicians in small practices (including those in rural locations), health professional shortage areas, and medically underserved areas may request technical assistance from organizations that can provide no-cost support. To learn more about this support, or to connect with your local technical assistance organization, we encourage you to visit our Small, Underserved, and Rural Practices page on the Quality Payment Program website.

For More Information

• To learn more about how to submit data, please review the resources available in the QPP Resource Library.
• Watch our series of data submission demo videos:
  • Introduction and Overview of 2019 Data Submission
  • File Upload and Quality Scoring
  • Manual Attestation of Improvement Activities
  • Manual Attestation of Promoting Interoperability Measures (coming soon)

Questions?

Please contact the Quality Payment Program at 1-866-288-8292, Monday through Friday, 8:00 AM-8:00 PM ET or by e-mail at: QPP@cms.hhs.gov.

To receive assistance more quickly, consider calling during non-peak hours—before 10 AM and after 2 PM ET. We also encourage you to contact us earlier in the year, as response times often increase with heavier demand as the March 31 data submission deadline approaches.

• Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.

Check Your Initial 2020 MIPS Eligibility on the QPP Website

You can now use the updated CMS Quality Payment Program Participation Status Lookup Tool to check on your initial 2020 eligibility for the Merit-based Incentive Payment System (MIPS).

Just enter your National Provider Identifier, or NPI, to find out whether you need to participate in MIPS during the 2020 performance period.

Low Volume Threshold Requirements

To be eligible to participate in MIPS in 2020, you must:

• Bill more than $90,000 a year in allowed charges for covered professional services under the Medicare Physician Fee Schedule (PFS), AND
• Furnish covered professional services to more than 200 Medicare Part B beneficiaries, AND
• Provide more than 200 covered professional services under the PFS.

If you do not exceed all three of the above criteria for the 2020 performance period, you are excluded from MIPS. However, you have the opportunity to opt-in to MIPS and receive a payment adjustment if you meet or exceed one or two, but not all, of the low-volume threshold criteria. Alternatively, you may choose to voluntarily report to MIPS and not receive a payment adjustment if you do not meet any of the low-volume threshold criteria or if you meet some, but not all, of the criteria.

Find Out Today

Find out whether you’re eligible for MIPS today. Prepare now to earn a positive payment adjustment in 2022 for your 2020 performance.

Note: The 2020 Eligibility Tool Update for QPs/APMs will be updated at a later time. Additionally, the tool will be updated in late 2020 to indicate final MIPS eligibility.

For More Information

• Visit the How MIPS Eligibility is Determined webpage on the Quality Payment Program website.
• View the 2020 QPP Final Rule Overview Fact Sheet.

Questions?

• Contact the Quality Payment Program at 1-866-288-8292, Monday through Friday, 8:00 AM-8:00 PM ET or by e-mail at: QPP@cms.hhs.gov. To receive assistance more quickly, consider calling during non-peak hours—before 10 AM and after 2 PM ET.
  • Customers who are hearing impaired can dial 711 to be connected to a TRS communications Assistant.

ASNR Sign On Letter Regarding “Protecting and Improving Medicare for our Nation’s Seniors”

Final Sign-on re 10-3 Executive Order

ASNR signs-on the Multi-society Pain Workgroup (MPW) Comment Letter to the Colorado Board of Health’s Department of Public Health and Environment

MPW Letter – CO Board of Health 10-14-2019