ASNR Advocacy Activities
CY 2025 Medicare Physician Fee Schedule Final Rule
Posted on: Nov 8 2024
Please visit the following weblink for the CY 2025 Medicare Physician Fee Schedule Final Rule: 2024-25382.pdf (federalregister.gov)
The CY 2025 Medicare Physician Fee Schedule Final Rule was released on November 1st, 2024. The 2025 Medicare conversion factor will decrease for the fifth straight year by approximately 2.83 percent from $33.2875 to $32.3465.
This cut is largely the result of the expiration of a 2.93 percent temporary update to the conversion factor at the end of 2024 and a 0 percent baseline update for 2025 under the Medicare Access and CHIP Reauthorization Act. Unfortunately, these cuts coincide with ongoing growth in the cost to practice medicine as CMS projects the increase in the Medicare Economic Index (MEI) for 2025 will be 3.5 percent.
The ASNR health policy team continues to review the final rule while advocating for physician reimbursement and preservation of our specialty. We plan on voicing our feedback and reccomendations via multiple channels in the following weeks.
Please see the following for estimated impacts to interventional radiology and radiology:
Specialty: Interventional Radiology
Allowed Charges (mil): $445
Impact of Work RVU Changes: 0%
Impact of PE RVU Changes: -2%
Impact of MP RVU Changes: 0%
Combined Impact: -2%
Specialty: Radiology
Allowed Charges (mil): $4,557
Impact of Work RVU Changes: 0%
Impact of PE RVU Changes: 0%
Impact of MP RVU Changes: 0%
Combined Impact: 0%
Please see the following impaced CPT codes that are stated in the final rule:
Percutaneous Radiofrequency Ablation of Thyroid (CPT codes 60660 and 60661)
CMS Comments: In January 2024, the RUC surveyed codes 60660 (Ablation of 1 or more thyroid nodule(s), one lobe or the isthmus, percutaneous, including imaging guidance, radiofrequency) and its respective add-on code 60661 (Ablation of 1 or more thyroid nodule(s), additional lobe, percutaneous, with imaging guidance, radiofrequency (List separately in addition to code for primary service) and recommended both work RVUs and PE values for this code family. For CPT code 60660, the RUC recommended a work RVU of 5.75 and we proposed the RUC-recommended work RVU of 5.75. For add-on code CPT 60661, the RUC recommended a work RVU of 4.25 and we proposed the RUC-recommended work RVU for this code. We also proposed the RUC recommended direct PE values for both codes 60660 and 60661. Finalized as proposed.
60660
Ablation of 1 or more thyroid nodule(s), one lobe or the isthmus, percutaneous, including imaging guidance, radiofrequency
Proposed CY 2025 Work RVU: 5.75
Final CY 2025 Work RVU: 5.75
60661
Ablation of 1 or more thyroid nodule(s), additional lobe, percutaneous, including imaging guidance,
radiofrequency (List separately in addition to code for primary procedure)
Proposed CY 2025 Work RVU: 4.25
Final CY 2025 Work RVU: 4.25
Guided High Intensity Focused Ultrasound (CPT code 61715)
CMS Comments: In September 2023, the CPT Editorial Panel created a new Category I code to describe magnetic resonance image guided high intensity focused ultrasound intracranial ablation for treatment of a severe central tremor that is recalcitrant to other medical treatments. This service is typically performed by a neurosurgeon without the involvement of a separate radiologist. This new code replaces the existing Category III code 0398T.
We did not propose the RUC-recommended work RVU of 18.95 for CPT code 61715 and instead proposed a work RVU of 16.60 based on a crosswalk to CPT code 61626 (Transcatheter permanent occlusion or embolization (eg, for tumor destruction, to achieve hemostasis, to occlude a vascular malformation), percutaneous, any method; non-central nervous system, head or neck (extracranial, brachiocephalic branch)), which describes a similar tumor destruction service that has similar time and intensity values to this service, and we support this value by referencing CPT code 33889 (Open subclavian to carotid artery transposition performed in conjunction with endovascular repair of descending thoracic aorta, by neck incision, unilateral) and 33894 (Endovascular stent repair of coarctation of the ascending, transverse, or descending thoracic or abdominal aorta, involving stent placement; across major side branches). We do not believe that this service is significantly more intense than the key reference codes, CPT codes 61736 (Laser interstitial thermal therapy (LITT) of lesion, intracranial, including burr hole(s), with magnetic resonance imaging guidance, when performed; single trajectory for 1 simple lesion) and 61737 (Laser interstitial thermal therapy (LITT) of lesion, intracranial, including burr hole(s), with magnetic resonance imaging guidance, when performed; multiple trajectories for multiple or complex lesion(s)), as the RUC-recommended work value implies. Our proposed work RVU of 16.60 for CPT code 61715 largely matches the intensity of CPT code 61736 which we believe is a more accurate valuation for this service, as opposed to the RUC recommendation which would have significantly more intensity. We proposed the RUC-recommended direct PE inputs for CPT code 61715 without refinement. After consideration of comments, it is agreed that CPT code 61715 is more accurately valued at the survey 25th percentile work RVU of 18.95 as recommended by the RUC based on their description of the complexity inherent to the procedure.
61715
Magnetic resonance image guided high intensity focused ultrasound (MRgFUS), stereotactic ablation of target, intracranial, including stereotactic navigation and frame placement, when performed
Proposed CY 2025 Work RVU: 16.60
Final CY 2025 Work RVU: 18.95
Magnetic Resonance Examination Safety Procedures (CPT codes 76014, 76015, 76016,
76017, 76018, and 76019)
CMS Comments: For CY 2025, new CPT codes 76014 and 76015 are PE only services that represent the preparatory research and review completed by clinical staff (that is, MRI technologist and/or a medical physicist) that will be utilized by the physician or qualified health professional for the other four services (CPT codes 76016, 76017, 76018, and 76019) in this code family. We proposed the RUC-recommended work RVU of 0.60 for CPT code 76016, the work RVU of 0.76 for CPT code 76017, the work RVU of 0.75 for CPT code 76018, and the work RVU of 0.60 for CPT code 76019.
76014
MR safety implant and/or foreign body assessment by trained clinical staff, including identification and verification of implant components from appropriate sources (eg, surgical reports, imaging reports, medical device databases, device vendors, review of prior imaging), analyzing current MR conditional status of individual components and systems, and consulting published professional guidance with written report; initial 15 minutes
Proposed CY 2025 Work RVU: 0
Final CY 2025 Work RVU:0
76015
MR safety implant and/or foreign body assessment by trained clinical staff, including identification and verification of implant components from appropriate sources (eg, surgical reports, imaging reports, medical device databases, device vendors, review of prior imaging), analyzing current MR conditional status of individual components and systems, and consulting published professional guidance with written report; each additional 30 minutes (List separately in addition to code for primary procedure)
Proposed CY 2025 Work RVU: 0
Final CY 2025 Work RVU:0
76016
MR safety determination by a physician or other qualified health care professional responsible for the safety of the MR procedure, including review of implant MR conditions for indicated MR examination, analysis of risk vs clinical benefit of performing MR examination, and determination of MR equipment, accessory equipment, and expertise required to perform examination, with written report
Proposed CY 2025 Work RVU: .60
Final CY 2025 Work RVU: .60
76017
MR safety medical physics examination customization, planning and performance monitoring by medical physicist or MR safety expert, with review and analysis by physician or other qualified health care professional to prioritize and select views and imaging sequences, to tailor MR acquisition specific to restrictive requirements or artifacts associated with MR conditional implants or to mitigate risk of non-conditional implants or foreign bodies, with written report
Proposed CY 2025 Work RVU: .76
Final CY 2025 Work RVU: .76
76018
MR safety implant electronics preparation under supervision of physician or other qualified health care professional, including MR-specific programming of pulse generator and/or transmitter to verify device integrity, protection of device internal circuitry from MR electromagnetic fields, and protection of patient from risks of unintended stimulation or heating while in the MR room, with written report
Proposed CY 2025 Work RVU: .75
Final CY 2025 Work RVU: .75
76019
MR safety implant positioning and/or immobilization under supervision of physician or other qualified health care professional, including application of physical protections to secure implanted medical device from MR-induced translational or vibrational forces, magnetically induced functional changes, and/or prevention of radiofrequency burns from inadvertent tissue contact while in the MR room, with written report
Proposed CY 2025 Work RVU: .60
Final CY 2025 Work RVU: .60
CT Guidance Needle Placement (CPT code 77012)
CMS Comments: CPT code 77012 (Computed tomography guidance for needle placement (eg, biopsy,aspiration, injection, localization device), radiological supervision and interpretation) was reviewed at the September 2023 RUC meeting to account for deferred updates to the vignette to reflect the typical patient until updated utilization data was available to reflect coding changes that occurred in 2019. We proposed the RUC-recommended work RVU of 1.50 for CPT code 77012. Finalized as proposed.
77012
Computed tomography guidance for needle placement (eg, biopsy, aspiration, injection, localization device), radiological supervision and interpretation CY 2024 Work RVU: 1.50
Proposed CY 2025 Work RVU: 1.50
Final CY 2025 Work RVU: 1.50
ASNR Advocacy Efforts
Posted on: Oct 24 2024
ASNR participated in advocacy efforts related to this letter. The letter is cosigned by members of Congress and urges House leadership to expeditiously replace the 2.8% cut with a payment update reflective of inflationary pressures before January 1, 2025. Read the letter here.
ASNR Signs-on Multi-Society Letter
Posted on: Oct 10 2024
ASNR signs-on multi-society comment letter submitted to the various MACs is in response to their updated Trigger Point Injection policies based on feedback they received. This specific letter was sent to CGS. Read the letter here.
ASNR Signs-on to Letter Regarding Closed-Loop SCS Coverage
Posted on: Oct 10 2024
ASNR signs-on the multi-society letter regarding Closed-Loop SCS coverage. The letter requests Humana to make their commercial coverage consistent with their MA policy. Read the letter here.
ASNR Signs-on Comment Letter to the WA HCA
Posted on: Oct 8 2024
ASNR signs-on comment letter regarding vertebroplasty, kyphoplasty, sacroplasty coverage to the WA HCA. The WA State HCA which covers 2.5. million residents through workers’ compensation, Medicaid, and State Employees have determined that vertebroplasty, kyphoplasty and sacroplasty are not a covered benefit since 2010. The HCA director selected VKS for rereview based on newly available evidence published which could change the original coverage determination. Read the full letter here.
ASNR Signs-on CF Coalition Drafted Letter to Congress
Posted on: Sep 4 2024
CMS has proposed a CY 2025 MPFS conversion factor that is roughly 2.8% below the current conversion factor. The current Medicare payment system is unsustainable. The letter is being sent to House and Senate leadership urging Congress to act prior to the end of 2024 to ensure that Medicare payments to clinicians in 2025 and beyond are adjusted to match inflation (MEI) and again emphasizing the need for permanent reform. Read the letter here.
ASNR Comments on 2025 Medicare Physician Fee Schedule
Posted on: Sep 4 2024
ASNR submits comment letter to CMS in regard to the Calendar Year (CY) 2025 Medicare Physician Fee Schedule Proposed Rule. Read the full letter.
ASNR Signs On to Letter to Congressional Leadership Regarding the Medicare Physician Fee Schedule Proposed Rule
Posted on: Jul 30 2024
ASNR signs on AMA letter to congressional leadership regarding the Medicare Physician Fee Schedule Proposed Rule that was released recently.
The CY 2025 proposed Medicare Physician Fee Schedule (MPFS) rule aims to cut Medicare physician payments by 2.8 percent, The 2025 Medicare conversion factor is set to decrease for the fifth straight year by approximately 2.80 percent from $33.2875 to $32.3562. This cut is largely the result of the expiration of a 2.93 percent temporary update to the conversion factor at the end of 2024 and a 0 percent baseline update for 2025 under the Medicare Access and CHIP Reauthorization Act (MACRA).
The letter also urges leadership to act on bills or future legislation which reforms MACRA along 4 keys pillars:
- Enacting an annual, permanent inflationary payment update in Medicare that is tied to the Medicare Economic Index (MEI) (H.R. 2474);
- Budget Neutrality reforms (H.R. 6371);
- An overhaul of MACRA’s Merit-based Incentive Payment System (MIPS); and
- Modifications to Alternative Payment Models (APM) (S. 3503/H.R. 5013).
ASNR Signs On to Letter Opposing the “Equitable Community Access to Pharmacist Services Act”
Posted on: Jul 30 2024
ASNR signs-on AMA letter to congressional leadership regarding opposing the “Equitable Community Access to Pharmacist Services Act.” This bill would allow pharmacists to perform services that would otherwise be covered if they had been furnished by a physician, test and treat patients for certain illnesses (including illnesses that address a public health need or relate to a public health emergency) and expand Medicare payment for pharmacists in limited but significant ways.
In April, the AMA sent a letter of opposition to the House, upon introduction of the bill. Because the legislation has amassed a considerable number of cosponsors the AMA believes it is important to show unified opposition within organized medicine to this bill. Read the letter here.
ASNR Signs-On to Letter Regarding Peripheral Nerve Stimulation
Posted on: Jul 8 2024
ASNR signs on multi-letter to Cigna in regard to peripheral nerve stimulation (PNS) for treating chronic pain. Cigna has deemed PNS not medically necessary. The multi-society letter advocates for coverage of PNS. Read the full letter here.
ASNR Signs-On to Multi-Society Letter Regarding Spinal Cord Stimulation
Posted on: Jun 17 2024
ASNR signs-on multi-society letter to the Washington State Health Care Authority. The letter applauds the recent proposed coverage policy changes regarding spinal cord stimulation (SCS) for the indications of failed back surgery syndrome, peripheral diabetic neuropathy (PDN) and nonsurgical refractory back pain (NSRBP). The letter additionally states concern with the draft findings proposed by the HTA Committee. The draft contains several elements that are poorly aligned with standard of care for SCS therapy. The letter provides further guidance for consideration to the Committee. Read the letter here.
Additional information and relevant materials can be viewed per the following link: https://www.hca.wa.gov/about-hca/programs-and-initiatives/health-technology-assessment/spinal-cord-stimulation
ASNR Signs-On to Multi-Society Letter Regarding Spinal Cord Stimulation
Posted on: May 30 2024
ASNR signs-on multi-society letter addressed to the Washington State Health Care Authority regarding the ongoing deliberations by the Health Technology Clinical Committee (HTCC) on Spinal Cord Stimulation (SCS). The letter also requests the HTCC invite clinical experts to present evidence-based coverage suggestions, re-review previous evidence-based presentations, and invite clinical experts to attend the next meeting to address questions and provide clarification to assist with decision-making. More information on the meeting, including meeting materials, can be found here. Read the full letter.
ASNR Signs-On to Multi-Society Letter in Response to UHC’s Negative Coverage Policy
Posted on: Mar 26 2024
ASNR signs-on multi-society letter in response to United Healthcare’s negative coverage policy for Basivertebral Nerve Ablation. View the policy here. Read the full letter.
ASNR Signs-On to Letter Supporting the Healthcare Workforce Resilience Act
Posted on: Mar 6 2024
ASNR signs-on a letter drafted by the Physicians for American Healthcare Access (PAHA) group that supports the bipartisan Healthcare Workforce Resilience Act. The act enables skilled immigrant nurses and physicians to secure robust permanent legal status in the United States. The bill will help alleviate the U.S. healthcare sector that is facing nationwide workforce challenges after shepherding the country through the paradigm-shifting challenge of the COVID-19 pandemic. Read the full letter here.
ASNR Signs-On to Letter Supporting the Science of Closed-Loop SCS
Posted on: Dec 1 2023
ASNR signs on letter drafted by the North American Neuromodulation Society (NANS) that support the science of closed-loop SCS. The letter has been submitted to several insurers. This letter was submitted to Cigna.
CY 2024 MPFS Final Rule Summary and Notes
Posted on: Nov 17 2023
CMS-1784-F
Medicare and Medicaid Programs; CY 2024 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; Medicare Advantage; Medicare and Medicaid Provider and Supplier Enrollment Policies; and Basic Health Program
Access: https://public-inspection.federalregister.gov/2023-24184.pdf
Conversion Factor: CMS has confirmed to the AMA that the 2024 Medicare conversion factor is $32.7442, not $32.7375 as identified in Table 116 and as previously reported. The decrease from the 2023 conversion factor is 3.37%.
New addition to Specialty Expected Assignment List (low volume services):
72255: Myelography thoracic spine
CMS has proposed to assign myelography of the thoracic spine to Diagnostic Radiology for purposes of practice expense calculation
PACS: The expert panel recognized that many non-radiology specialties are increasingly adopting a “picture archiving and communication system (PACS)” for image storage and important patient care. However, the RUC has previously indicated that these are general practice expenses not typically allocated to a single patient/code and that only the specific use of the PACS workstation is acceptable under PE supplies. As many PACS vendors increasingly shift to a per-patient cost, the RUC may need to reconsider how these supplies are allocated in practice expense.
AUC: While these initiatives, including the Shared Savings Program, do not specifically target advanced diagnostic imaging, the expectation is that this is more of a global approach to improving quality and accountable care would broadly affect all services, including advanced diagnostic imaging utilization. Both ACO participation and episode of care payment models promote accountability for beneficiary cost of care as well as improving or maintaining quality of care according to applicable quality measures. Similarly, the MIPS ties together quality and costs by measuring and scoring performance in four performance categories: quality, cost, improvement activities, and promoting interoperability. MIPS uses measures and activities in each of these categories, such as the Total Per Capita Cost (TPCC) specialty measure, which focuses on effective primary care management to support Medicare savings. While also not specific to advanced diagnostic imaging, improvements in primary care management including ordering of diagnostic tests may involve consideration of appropriate imaging orders. More specific to advanced diagnostic imaging, MIPS includes 10 specific quality measures pertaining to imaging or under the “Diagnostic Radiology” Specialty Measure Set. Additionally, the Meaningful Measures 2.0 Framework includes a priority area for safety with the goal of “Reduced Preventable Harm” (https://edit.cms.gov/files/document/cascademeaningful-measures-framework.xlsx). An objective under this goal is “Diagnostic Accuracy/Error” which includes a cascade measure concept/family of “Appropriate use of radiology and lab testing.” An example of an existing measure within this concept is “Appropriate Follow-up Imaging for Incidental Abdominal Lesions” (https://www.cms.gov/files/document/cascade-measures.xlsx). While a standalone program specifically requiring AUC consultation when ordering advanced diagnostic imaging services would directly target goals of improving advanced diagnostic imaging ordering patterns, experience in recent years has demonstrated that the goals of appropriate, evidence based, coordinated care can be achieved more effectively, efficiently and comprehensively through other CMS quality initiatives.
CY 2024 PFS Estimated Impact on Total Allowed Charges by Specialty
INTERVENTIONAL RADIOLOGY
Allowed Charges (mil) $458
Impact of work RVU Changes -1%
Impact of PE RVU Changes-3%
Impact of MP RVU Changes 0%
Combined Impact -4%
RADIOLOGY
Allowed Charges (mil) $4,536
Impact of work RVU Changes 1%
Impact of PE RVU Changes-2%
Impact of MP RVU Changes 0%
Combined Impact-3%
The estimated impacts for several specialties, including anesthesiology, interventional radiology, radiology, nuclear medicine, vascular and thoracic surgery, physical/occupational therapy, anesthesiology, and audiology, reflect decreases in payments relative to payment to other specialties, largely resulting from the redistributive effects of the implementation of separate payment for the O/O E/M visit inherent complexity add-on code, the Year 3 update to clinical labor pricing, and/or the proposed adjustment to certain behavioral health services. The services furnished by these specialties were negatively affected by the redistributive effects of increases in work RVUs for other codes, and/or rely primarily on supply/equipment items for their practice expense costs and, therefore, were affected negatively by the updated Year 3 clinical labor pricing under budget neutrality. These decreases are also due to the revaluation of individual procedures based on reviews, including consideration of AMA RUC review and recommendations, as well as decreases resulting from the continued phase-in implementation of the previously finalized supply and equipment pricing updates. The estimated impacts also reflect decreases due to the continued implementation of previously finalized code-level reductions that are being phased in over several years. For independent laboratories, it is important to note that these entities receive approximately 83 percent of their Medicare revenues from services that are paid under the CLFS.
ASNR Signs On to a Payment Coalition Letter to Congressional Leadership
Posted on: Nov 14 2023
ASNR signs-on Payment Coalition letter to the House and Senate Leadership urging them to stop the full 3.4% conversion factor reduction prior to the end of the year. The letter references G2211 being the driver of the budget neutrality reduction, rising medical practice costs (MEI) and the need for long term Medicare payment reform. Read the letter here.
ASNR Signs-On to Letter Regarding the GOP Doctors Caucus Budget Neutrality Reform
Posted on: Nov 6 2023
ASNR signs-on AMA Federation letter to the Hill regarding the GOP Doctors Caucus budget neutrality reform proposal. The letter stresses urgency for taking Congressional action on budget neutrality policies. Read the full letter here.
ASNR Sign-On to Letters Regarding Code G2211
Posted on: Oct 17 2023
ASNR signs-on multi-society letters addressed to both the House and Senate outlining concerns and urging Congress to act prior to the end of the year to permanently halt implementation of this code (G2211), which is responsible for 90% of the budget neutrality reduction to the conversion factor in CY 2024 MPFS proposed rule. Read the House letter. Read the Senate letter.
ASNR/ASSR Signs On to Multi-Society Letter
Posted on: Oct 10 2023
ASNR/ASSR sign-on a multi-society letter to the Washington State Health Care Authority that advocates for providing patients in Washington access to Spinal Cord Stimulation (SCS). Read the letter here.
ASNR Signs On to American Brain Coalition Letter
Posted on: Sept 28 2023
ASNR signs-on multi-society letter drafted by the American Brain Coalition. The letter requests robust funding for the BRAIN Initiative in Fiscal Year 2024, emphasizing that the Initiative is revolutionizing our understanding of the human brain and making progress toward treatments and cures for numerous diseases and disorders. Additionally, the letter states that any funding cuts to the BRAIN Initiative will have a damaging effect on neuroscience research. Read the letter.
ASNR Submits Comments to CMS
Posted on: Sept 18 2023
ASNR submits comments to CMS regarding the CY 2024 physician fee schedule proposed rule. Read the comments here.
ASNR and ASSR Sign-On a Multi-Society Letter
Posted on: Sept 18 2023
ASNR and ASSR sign-on a multi-society letter to Noridian that suggests revisions to their recently proposed LCD on Intraosseous Basivertebral Nerve Ablation. Read the letter here.
ASNR Summary of Proposed Rule July 2023
Posted on: Jul 24 2023
Conversion Factor:
2024 Medicare conversion factor is proposed to be reduced by 3.36 percent from $33.8872 to $32.7476. The CMS Press Release states the decrease is 3.34 percent, but AMA believes this is an error. These cuts coincide with ongoing growth in the cost to practice medicine as CMS projects the increase in the Medicare Economic Index (MEI) for 2024 will be 4.5 percent.
MEI:
Additionally, In the CY 2024 proposed rule, CMS announced that they will continue to postpone implementation of the updated MEI weights, referencing the AMA’s national study to collect representative data on physician practice expenses, the AMA Physician Practice Information (PPI) Survey. The PPI Survey launches on July 31st, 2023, and data is anticipated to be shared with CMS in early 2025.
MIPS:
CMS also proposes to increase the performance threshold to avoid a penalty in the Merit-based Incentive Payment System (MIPS) from 75 points to 82 points. CMS estimates this would result in an increase in the number of MIPS eligible clinicians who would receive a penalty of up to –9 percent.
Electronic Clinical Quality Measure:
Due to AMA advocacy, CMS proposes to delay mandatory electronic clinical quality measure (eCQM) adoption by Medicare Shared Savings Program (MSSP) participants and may continue to utilize the CMS Web Interface in 2024.
Removal of Regulations-AUC Consultation:
While a standalone program specifically requiring AUC consultation when ordering advanced diagnostic imaging services would directly target goals of improving advanced diagnostic imaging ordering patterns, our experience in recent years has demonstrated that the goals of appropriate, evidence based, coordinated care can be achieved more effectively, efficiently and comprehensively through other CMS quality initiatives.
Estimated Impact on Total Charges:
Interventional Radiology:
Allowed Charges (mil): $457
Impact of Work RVU Changes: -1%
Impact of PE RVU Changes: -3%
Impact of MP RVU Changes: 0
Combined Impact: -4%
Estimated Impact on Total Charges:
Radiology
Allowed Charges (mil): $4,517
Impact of Work RVU Changes: -1%
Impact of PE RVU Changes: -2%
Impact of MP RVU Changes: 0
Combined Impact: -3%
Utilization by provider specialty impact across a number of health equity dimensions
Total # of Enrollees: 28,285,281
Total # of Services: 2,504,984,961
Radiology
Total number of Services (Radiology):181,430,147
White: 81.4 %
Black: 6.7%
Hispanic: 5.3%
Asian American and Pacific Islander: 2.8%
American Indian and Alaska Native: 0.3%
SDOH: 0.0%
Behavioral Health: 0.4%
End Stage Renal Disease: 1.4%
Area Deprivation Index: 5.3%
Low Income Subsidy: 15.0 %
Medicare Medicaid Dually Enrolled: 14.0 %
Low income Subsidy/ Medicare Medicaid Dually Enrolled: 15.1 %
Non-Metro:14.3 %
Disability: 17.6%
The text of the proposed rule can be accessed at: https://public-inspection.federalregister.gov/2023-14624.pdf.
National Study to Document Changes in Physician Practice Expense
Posted on: Jul 24 2023
The American Medical Association (AMA) is undertaking a new national study, supported by 173 healthcare organizations, to collect representative data on physician practice expenses. The aim of the Physician Practice Information (PPI) Survey is to better understand the costs faced by today’s physician practices to support physician payment advocacy. The study will serve as an opportunity to communicate accurate financial information to policymakers, including members of Congress and the Centers for Medicare & Medicaid Services (CMS). The AMA has contracted with Mathematica, an independent research company with extensive experience in survey methods as well as health care delivery and finance reform, to conduct the study.
The Medicare physician payment schedule, maintained by CMS and used by many other payers, relies on 2006 cost information to develop practice expense relative values, the Medicare Economic Index and resulting physician payments. As the U.S. economy and health care system have undergone substantial changes since that time, including inflation and the wide-spread adoption of electronic health records and other information technology systems, practice expense payments no longer accurately reflect the relative resources that are typically required to provide physician services.
The study will rely on financial experts in the practice to complete an online financial information survey. The number of direct patient care hours is a critical component of the Medicare payment methodology. Therefore, thousands of individual physicians will receive a short patient care hours survey from either their practice directly or from Mathematica. The input from physician practices and individual physicians that are randomly selected to participate in this study is critical for its success. Participation will ensure that practice expenses and patient care hours are accurately reflected.
ASNR Signs On to Letter to BCBS of Tennessee
Posted on: Jul 7 2023
ASNR and ASSR have signed on the attached multi-society letter that provides feedback to BCBS of Tennessee regarding the draft medical policy for Implantable Peripheral Nerve Stimulation (PNS) Devices as a Treatment for Pain. This draft language has created significant concern among the pain medicine community given the increasingly important role that PNS plays in the management of persistent and chronic pain. The letter supports coverage. Read the letter.
ASNR Signs-On in Opposition to “I CAN Act”
Posted on: Jun 10 2023
ASNR signs on AMA drafted multi-society letter that strongly opposes H.R. 2713, the “Improving Care and Access to Nurses Act,” or the “I CAN Act.” This legislation would endanger the quality of care that Medicare and Medicaid patients receive by expanding the scope of practice for nonphysician practitioners, including nurse practitioners, certified nurse midwives, certified registered nurse anesthetists, clinical nurse specialists, and physician assistants. Read the letter here.
ASNR Signs-On to Congressional Letter Regarding Medicare Physician Payments
Posted on: May 18 2023
ASNR signs-on multi-society letter addressed to Representatives Ruiz, Bucshon, Bera, and Miller-Meeks. The letter shares the importance of providing an annual inflation update equal to the Medicare Economic Index (MEI) for Medicare physician payments. The letter states that doing so is essential to enabling physician practices to better absorb payment distributions triggered by budget neutrality rules, performance adjustments, and periods of high inflation. It will also help physicians invest in their practices and implement new strategies to provide high-value care. Read the letter here.
ASNR Signs-On to a Pain Workgroup Letter
Posted on: May 18 2023
ASNR signs-on multi-society pain workgroup letter addressed to several commercial payer’s Medical Directors that continue to require 4-6 weeks of conservative management prior to treatment for the vertebral compression fracture (VCF). The letter supports the need to align commercial and Medicare coverage policies for percutaneous vertebral augmentation (PVA). Read the letter to Aetna.
ASNR Signs-On Multi-Society Letter to Cigna
Posted on: Apr 27 2023
ASNR signs-on multi-society letter requesting Cigna immediately rescind its policy requiring submission of office notes with all claims including evaluation and management (E/M) Current Procedural Terminology (CPT®) codes 99212, 99213, 99214, and 99215 and modifier 25 when a minor procedure is billed.
Cigna recently notified network providers that payment will be denied for E/M services reported with modifier 25 if records documenting a significant and separately identifiable service are not submitted with the claim. The letter urges Cigna to reconsider this policy due to its negative impact on practice administrative costs and burdens across medical specialties and geographic regions, as well as its potential negative effect on patients, and instead partner with organizations on a collaborative educational initiative to ensure correct use of modifier 25. Read the full letter.
ASNR Signs-On to a Letter Regarding the Importance of the Physician Practice Information Survey
Posted on: Apr 13 2023
ASNR signs-on a letter with several state medical associations, national medical specialty societies, and other health care organizations to convey an important message that the Physician Practice Information Survey is essential to the collection of practice cost information for use in advocacy to support physicians. The data from the survey will be shared with the Centers for Medicare & Medicaid Services in late 2024 to update the Medicare Economic Index and the Resource-Based Relative Value Scale. Read the letter here.
ASNR Signs-On to Letter Regarding FY 2024 Funding Recommendation
Posted on: Mar 22, 2023
ASNR signs-on letter drafted by the Ad Hoc Group regarding the FY 2024 funding recommendation. The recommendation supports at least $50.924 billion for NIH’s foundational work. It is a $3.465 billion increase over the comparable FY 2023 program level. Read the full letter.
ASNR Signs-On to Letter to Congress Urging Them to Address the Medicare Physician Fee Schedule
Posted on: Mar 22, 2023
ASNR signs-on letter with the AMA and 134 other health organizations representing 900,000 physicians and tens of millions of Medicare patients. The letter addresses congressional leaders stating to them that a full inflation-based update is “the principal legislative solution to the ongoing problems plaguing the Medicare Physician Fee Schedule.” The letter urges Congress to provide physicians with much needed fiscal stability by passing legislation that provides an annual inflation-based payment update based on the full Medicare Economic Index (MEI). Read the full letter.
ASNR Signs-On to Letter Regarding Proposed Medicare Part C and D Rule
Posted on: Feb 22, 2023
ASNR signs-on AMA drafted letter to CMS regarding the proposed Medicare Part C and D rule. The letter highlights and encourages finalization of some extremely positive changes to prior authorization policy in MA plans as a group.
The proposed prior authorization reforms include:
- Increased clinical validity of coverage criteria
- Restrictions on retroactive denials after prior authorization approvals
- A grace period for patients switching plans to promote continuity of care
- Greater physician-patient autonomy in determining where care can be provided and by whom
- Volume reduction by encouraging gold carding programs
- Prior authorization information at the point-of-care.
ASNR Signs On to Letter Emphasizing Need for Medicare Payment Reform
Posted on: Jan 31 2023
ASNR signs on a multi-society coalition letter emphasizing the need for substantive Medicare payment reform, calling on Congress to hold hearings as soon as possible to begin exploring potential payment solutions and reiterates the coalition’s desire to work with them on permanent reform. Read the letter here.
CMS Updates National Medicare Physician Payment Files
Posted on: Jan 9 2023
The Centers for Medicare and Medicaid Services has alerted the American Medical Association that the agency has released updated national Medicare physician payment files that incorporate the changes in the Consolidated Appropriations Act of 2023. Specifically, in response to concerted advocacy by organized medicine, Congress reduced the 4.5% cut to Medicare physician payment by increasing the 2023 conversion factor by 2.5%. The updated 2023 Medicare physician payment schedule conversion factor will be $33.8872. The previously finalized conversion factor was $33.0607. The 2022 conversion factor was $34.6062.
House Leadership Urged to Adopt H.R. 3541
Posted on: Dec 12 2022
Representatives Brad Schneider (D-IL) and Don Bacon (R-NE) distributed the letter to House leadership urging adoption of H.R. 3541 within a forthcoming end-of-the-year bill (H.R. 3541/S. 1810, the Conrad State 30 and Physician Access Reauthorization Act). The Conrad 30 program has helped to address physician shortages, especially in rural communities, by bringing thousands of American-trained physicians from other countries to medically underserved communities. It does so by allowing foreign doctors on J-1 visas to remain in the United States after they finish their medical training if they agree to spend three years practicing in an underserved area. Reauthorization and expansion of the program will allow rural and underserved communities to continue to benefit from the talents and expertise of foreign physicians who are eager to serve where they are needed most. Read the full letter.
ASNR Signs On to Conversion Factor Coalition Letter
Posted on: Dec 12 2022
ASNR signs-on a multi-society Conversion Factor Coalition letter. The coalition letter is to the House and Senate leadership focusing on the need for Congress to act to eliminate the entire 4.5% reduction before the end of the year. Read the letter here.
ASNR Sends Letter in Opposition to H.R. 8812
Posted on: Nov 7 2022
The letter is addressed to Chairmen Neal and Pallone and Ranking Members Brady and McMorris Rodgers expressing our strong opposition to H.R. 8812, the “Improving Care and Access to Nurses Act,” or the “I CAN Act.” This legislation would endanger the quality of care that Medicare and Medicaid patients receive by expanding the scope of practice for non-physician practitioners (NPPs), including nurse practitioners (NPs), certified nurse midwives (CNMs), certified registered nurse anesthetists (CRNAs), clinical nurse specialists (CNS), and physician assistants (PAs). Read the full letter.
CMS Releases the 2023 Medicare Physician Payment Schedule Final Rule
Posted on: Nov 7 2022
The Centers for Medicare & Medicaid Services (CMS) released the 2023 Medicare Physician Payment Schedule final rule: https://www.cms.gov/files/document/cy2023-physician-fee-schedule-final-rule-cms-1770f.pdf
Conversion Factor:
The CY 2023 Medicare conversion factor (CF) is $33.06, a decrease of $1.55 or 4.5% from the 2022 CF of $34.61. The decrease is largely a result of an expiring 3 percent increase funded by Congress through 2022. The additional approximate 1.6% decrease is the result of budget neutrality requirements that stem from the revised E/M changes.
Impact to Radiology:
Radiology
Allowed charges (mil): $4,734
Impact of work RVU changes: -1%
Impact of Practive Expense RVU changes: -1%
Impact of Malpractice RVU changes: 0%
Combined impact: -2%
ASNR continues to work with coalitions formed by ACR/AMA to lobby for Congressional intervention to mitigate cuts.
Please read the full Senate colleague letter to leadership that addresses payment cuts.
ASNR Signs-On to Letter Advocating for Coverage for Sacroiliac Joint Injections and Procedures
Posted on: Oct 14 2022
ASNR signs-on multi-society comment letter to Palmetto regarding their proposed LCD on Sacroiliac Joint Injections and Procedures. Palmetto’s draft LCD on SIJ RFA deems sacroiliac joint RFA as not medically necessary. The comment letter that was submitted advocates for coverage. Read the full letter here.
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.
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
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.
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 21st 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
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
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.
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).
AMA Urges Governors to Adopt Emergency Response Protections for Physicians
Posted on: Apr 23 2020
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
ASNR signs-on AMA drafted multi-society letter regarding HHS emergency funding
Posted on: Apr 23 2020
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
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
ASNR/ASSR signs-on letter in response to the vertebral augmentation LCD published by Noridian
Posted on: Mar 30 2020
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
- S. Census Bureau, 2017 National Population Projections, Projections of Race and Hispanic Origin, 2017-2050.
- 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].
- Rock, D., Grant, H. (2016). Why Diverse Teams are Smarter. HBS No. H038YZ. Boston, MA: Harvard Business School Publishing.
- 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
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
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.
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:
- Go to the Quality Payment Program website
- Sign in using your QPP access credentials (see below for directions)
- 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
