Presented by:

Denise A. Merlino, MBA, CNMT, CPC, FSNMTS

Reimbursement Update – Efforts for Changes to Medicare

Hospital Payment Policy (HOPPS)

2-29-2016

Presenter & Disclosures

Denise Merlino, MBA, CNMT, FSNMMI, CPC

President, Merlino Healthcare Consulting Corp.

Gloucester, MA

merlinohccc@gmail.com

2

Consultant to: SNMMI & ACNM & ASNC

Bracco & UPPI & Pharmalucence

American Thoracic Society (ATS)

American College of Chest Physicians (CHEST)

American Geriatrics Society (AGS)

American Society for Clinical Oncology (ASCO)

Renal Physicians Association (RPA)

Topics – Medicare

1. Current Status of Medicare Payment Policy

• Hospital Outpatient (aka HOPPS)

• Charge Masters - Slow Adoption - Charge Compression

2. Initiative Addressing Coding & Billing Errors

• Rp to Procedure Code Edits

• A prospective, proactive solution for inappropriate payments

3. Alternative APC Group Configurations

• Consolidation of Procedure APC Groups

• Creation of diagnostic radiopharmaceutical APC Groups

• Use of voluntarily supplied Average Sales Price for

Diagnostic Radiopharmaceuticals

3

1. CURRENT STATUS

MEDICARE PAYMENT POLICY

Hospital Outpatient Payment System (HOPPS)

4

5

Hospital

Inpatient IPPS/DRG

On Campus-

Hospital

Outpatient

OPPS/APC

Off Campus-

Hospital

Outpatient

OPPS/APC

Physician

outpatient

Services RBRVS/MPFS

Imaging

outpatient Centers (IDTF)

RBRVS/MPFS

POS 21 22 19 11 The setting the beneficiary

received the technical

component (TC) of the service.

Medicare

program

dollars Part A Part B

Local

Medicare contractors/ administrators

of the policies

Fiscal Intermediaries (old) Carriers (old)

Medicare Administrative Contractors (MAC) (Current)

www.cms.hhs.gov/medicarecontractingreform/

Abbreviations: APC, Ambulatory Payment Classifications; DRG, Diagnosis-

Related Groups; HOPPS, Hospital Outpatient Prospective Payment System;

IPPS, Inpatient Prospective Payment System; MPFS, Medicare Physician Fee

Schedule; RBRVS, Resource-Based Relative Value System, POS, Place of

Service IDTF, Independent Diagnostic Testing Facilities

POS 15 = Mobile Unit / Facility/ unit that moves from place-to –place

equipment to provide diagnostic and or treatment services.

Slide copyright MHCCC 2016

Medicare Payment Systems Basic Comparison of MPFS vs HOPPS

• MPFS is a system that pays for covered physicians’ services furnished to a person outside of a hospital.

• Under the MPFS a relative value (RVU) is assigned to each service to capture the direct and indirect (overhead) practice expenses typically involved in furnishing the service. AMA along with professional societies develop inputs and values by survey not claims data.

• The higher the number of relative value units (RVUs) assigned to a service, the higher the payment.

• Radiopharmaceuticals are paid at AWP or invoice cost.

• Drugs are paid at ASP + 6%.

• All services under the HOPPS are technical and are classified into groups called Ambulatory Payment Classifications (APCs) groups. Services in each APC are grouped by clinically similar services that require the use of similar resources.

• A payment rate is established for each APC using two year old hospital claims data adjusted by individual hospital’s cost to charge ratios.

• The APC national payment rates are adjusted for geographic cost differences with payment rates and policies being updated annually through rulemaking.

• Currently, diagnostic radiopharmaceuticals are bundled into the APC rate and considered supplies.

Charge (Description) Master

When to Update the CDM?

• Minimum Annual Update with Coding Changes

• October thru December each year

• Changes in Payer Guidelines or Instructions

• Changes in Technology

• Changes in Pricing

• Department Provides New Services or New Product Lines

• CMS Quarterly Updates (HCPCS & APC) Updates

• January, April, July, October

7

Diagnostic – Thyroid, Parathyroid & Adrenal

HOPPS National Rates Includes the Diagnostic Radiopharmaceutical(s) & Bundled Ancillary for CY 2016

APC rates will vary geographically. Figures used are not actual hospital payment rates.

CPT ® is a registered trademark of the American Medical Association

HCPCS

Code Descriptor

HOPPS

2013 Rate

HOPPS

2014 Rate

HOPPS

2015 Rate

HOPPS

2016 Rate

78014 Thyroid uptake & scan $232.94 $286.94 $281.89 $332.65 +18%

78070 Parathyroid planar $232.94 $286.94 $281.89 $332.65 +18%

78071 Parathyroid planar &

SPECT $322.04

CH APC 0317

$738.69 CH APC 0317

$377.18 CH APC 0263

$332.65 (-12%)

78072 Parathyroid planar &

SPECT /CT $322.04 $738.69 $377.18 $441.36 +17%

78075 Adrenal Imaging $955.60 $1,157.42 $1,188.28 $1,108.46 (-7%)

78195 Lymphatics $275.95** $346.34** $369.60** $332.65** (-10%)

**A9520 Lymphoseek packaged for CY 2016, off pass-through per statute.

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Dept # Item # Limited Description CPT/HCPC RC Price Active

Code

Deactivation/

Date

302 55486 Tumor SPECT – (Parathyroid) 78803-TC 0341 $3,200.00 Y Maybe

302 55450 Parathyroid Imaging (planar) 78070-TC 0341 $1,800.00 Y Modified

302 55490 Parathyroid Planar + SPECT 78071-TC 0341 $3,200.00 Y New

302 55410 Parathyroid Planar + SPECT/CT 78072-TC 0341 $4,200.00 Y New

302 40335 Tc99m pertechnetate, per mCi A9512 0343 $100.00 Y

302 40350 Tc99m sestamibi, PSD A9500 0343 $500.00 Y

Charge Description Master

Parathyroid Imaging Effective 1/2013

PSD = per study dose

Price = example to show math and not derived from actual data

TIP: Maintain the tumor SPECT code unless you priced it differently from other

tumor imaging. Price for SPECT without CT should be different from SPECT with

CT for attenuation correction (AC) service Watch units for RPs.

®CPT is a registered trademark of the American Medical Association

9

What is “Charge Compression”?

• Hospitals do not mark-up high cost drugs in the

same way as they mark up lower cost drugs.

• Example low cost: 99mTc MDP $22.00, on CDM at $55

this is a 250% mark up

• Example high cost: PET agent $3,000.00, on CDM at

$3,500 117% mark up rather than $7,500.00

• Therefore when CMS uses one cost-to-charge

ratio for a hospital the costs of the higher cost

drugs or radiopharmaceuticals are undervalued for

rate setting.

10

Example I-123 mIBG AdreviewTM: CMS Data: Cost Versus ASP Plus 6

HCPCS

Level II

Total

Units Descriptor

Mean

Cost

Oct 2011

OPPS

Addendum B

File

F CY 2011

A9582 2012 Data

403

Iodine I-123 iobenguane,

diagnostic, per study

dose, up to 15 millicuries

$1,331.73

$2,636.16 A9582

2013 Data 402 $1,380.34

A9582 2014 Data

328 $1,455.44

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G.E. (manufacturer of product) ASP Q2 2013 = $2,696.00

ASP+ 6

Pass-Through

The cost of this diagnostic radiopharmaceutical (A9582) is a significant

cost (CMS definition of >40%) to consider for any APC placement.

CMS should consider a policy to address nuclear medicine services that

are Radiopharmaceutical cost intense and likely low volume.

Example: I-123 mIBG AdreviewTM

APC Packaged Rates

Cost of RP = Loss to Hospital

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HCPCS Code Descriptor HOPPS

2013 Rate

HOPPS

2014 Rate

HOPPS

2015 Rate

HOPPS

2016 Rate

78075 Adrenal Imaging

$955.60 $1,157.42 $1,188.74

$1,108.46 78804 2 or more day Tumor Imaging

0331T &

0332T

Myocardial sympathetic innervation,

imaging, planar qualitative and

quantitative assessment;

And with tomographic SPECT

$679.68 Incl Dx RP,

WM & EF

$1,153.62 Incl Dx RP, WM,

EF, 93017, Stress

Agent

$1,140.54 Incl Dx RP, WM, EF,

93017, Stress Agent

A9582 Iodine I-123 iobenguane, diagnostic,

per study dose, up to 15 millicuries Packaged Packaged Packaged Packaged

CPT ® is a registered trademark of the American Medical Association

APC rates will vary geographically. Figures used are not actual hospital payment rates.

A9582

RP Cost (ASP Q2 2013)

HOPPS Payment 2016 Hospital Loss

$2,696.00 APC 5593 $1,108.46 ($1,587.54)

Example: Diagnostic Radiopharmaceutical

Off Pass-Through Status Cost of Dx RP will exceed APC packaged payment rate

**C1204 LymphoSeek Oct 2013 - A9520 CY 2014 & 2015 on pass-through per statute off-set applies; CY 2014 offset APC 0400,

$61.41, 0392 $71.31. CY 2015 offset 0400, $62.96, 0392 $73.88 CY 2016 Lymphoseek off pass-through status, RP is packaged.

HCPCS

Code Descriptor

HOPPS

2014 Rate

HOPPS

2015 Rate

HOPPS

P 2016 Rate

HOPPS

F 2016 Rate

78195 Lymphatics and lymph node $346.34** $369.60** $336.75

(-8.9%)

$332.65

(-10%)

38792 “Q1” Status

Inj, proc. Radioactive tracer

for ID of sentinel node $257.43** $280.27**

$254.47

(-9.2%)

$332.65

(19%)

A9520 Tc99 tilmanocept diag 0.5mci $240.00

ASP +6 Jan 1, 2014 rate

$497.00

ASP +6 Oct 1, 2015 rate

Packaged

Off Pass-

through

Packaged

Off Pass-through

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A9520

RP Cost (ASP Oct 1, 2015) HOPPS Payment

2016

Hospital Loss

$497.00 APC 5591 $332.65 (-$164.35)

APC rates will vary geographically. Figures used are not actual hospital payment rates.

CPT ® is a registered trademark of the American Medical Association

Hospital Claim Cost Data 2012 & 2014

Used to set 2014 & 2016 Rates

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Slow changes – HOPPS claims data

When prices increase it can take years to show up in payment rates

Pass-Through Payment for New

Procedures-Radiopharmaceuticals

Legislated: (CMS has no authority to modify)

• Diagnostic Radiopharmaceuticals do

qualify for transitional pass-through

payment status

• However, this is for minimum 2 years

not to exceed 3 years…then by CMS

policy would be bundled 15

IDEAS-Study.org

Diagnostic Radiopharmaceutical (Dx Rp) Payment Pass-Through or Contractor Priced

Must participate in CED Trial for Amyloid Agents

2016 HCPCS Level II Codes

HCPCS

Level II

Trade

Name

Company Description

2016

SI /

APC

2016

HOPPS

Payment

2016

MPFS

Payment

C9458 *A9599

Neuracec™ Piramal

NDC # 54828-001-30

Florbetaben F-18, diagnostic, per

study dose, up to 8.1 millicuries G

9458 $2,968.00 Contractor

Priced

Most likely at

Invoice Cost.

* This setting

typically does

not accept C

codes, use

A9599

C9459 *A9599

Vizamyl™ G.E. NDC #

17156-067-10 17156-067-30

Flutemetamol F-18, diagnostic,

per study dose, up to 5 millicuries G

9459 $3,135.00

A9586

Amyvid™ Lily

NDC #

0002-1200-01

Florbetapir F-18, diagnostic, per

study dose, up to 10 millicuries G

1664 $2,756.00

© 2010 MEDICAL LEARNING INCORPORATED / SLIDE 16 16

IDEAS-Study.org

Procedure Coding - IDEAS

CPT Code Description 2016 HOPPS National Rate

2016 MPFS NF National Rate

78811-Tc PET imaging; limited area (eg, chest, head/neck)

$1,285.17- $228.37 = $1,056.80

$1,285.17 OPPS CAP 78814-Tc PET w/ CT for AC and

anatomic localization imaging; limited area (eg, chest, head/neck)

2016 Off-set only applies for HOPPS setting technical: APC 5594 = $228.37

NF= Non-Facility, Physician Office, Independent Diagnostic Testing Facility Setting (IDTF)

Rates will vary geographically. Figures are national rates.

2. INITIATIVE ADDRESSING

CODING & BILLING ERRORS

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RP to Procedure Code Edit Data

HOPPS Claims Analysis

19

RP to Procedure Code Edit

Project from claims Analysis

20

National Correct Coding Initiative

SNMMI working with NCCI contractor

• SNMMI Letter recommending diagnostic

radiopharmaceutical to procedure code edits was

sent to NCCI contractor and follow up meeting

February/ March 2015.

• NCCI contractor & CMS accepted SNMMI

recommended edits:

• NCCI version 21.3 implemented on October 1, 2015. Other

societies could have submitted comments by July 1, 2015 if they

disagreed with any of the edits, however none did.

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Results: SNMMI Edit Project

Slow – Long term project

• CMS & the SNMMI have received many inquiries from

providers that had denied claims

• SNMMI and the NCCI contractor educated providers on

proper coding for the diagnostic and therapeutic

radiopharmaceuticals.

• Since CMS is using HCPCS codes for bundling payments in

APCs, the hope is that by educating the hospitals, CMS

hospital claims data will get better.

• This is a long term project, since in HOPPS CMS uses two

year old data to set payment rates.

3. ALTERNATIVE APC GROUP

CONFIGURATIONS

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CY 2015 CMS - Nuclear Medicine

Current APC Restructure # APC Group Title SI Payment

Rate 1 0308 Positron Emission Tomography (PET) imaging S $1,285.72 2 0317 Level II Miscellaneous Radiology Procedures S $812.89 3 0340 Level II Minor Procedures S $52.35 4 0377 Level II Cardiac Imaging S $1,140.10 5 0378 Level II Pulmonary Imaging S $440.17 6 0389 Level I Non-imaging Nuclear Medicine S $189.08 7 0390 Level I Endocrine Imaging S $189.85 8 0391 Level II Endocrine Imaging S $281.89 9 0392 Level II Non-imaging Nuclear Medicine S $280.16

10 0393 Hematologic Processing & Studies S $627.95 11 0394 Hepatobiliary Imaging S $372.91 12 0395 GI Tract Imaging S $326.83 13 0396 Bone Imaging S $332.18 14 0398 Level I Cardiac Imaging S $373.42 15 0400 Hematopoietic Imaging S $369.46 16 0401 Level I Pulmonary Imaging S $315.76 17 0402 Level II Nervous System Imaging S $557.03 18 0403 Level I Nervous System Imaging S $176.99 19 0404 Renal and Genitourinary Studies S $420.49 20 0406 Level I Tumor/Infection Imaging S $377.18 21 0407 Radionuclide Therapy S $276.82 22 0408 Level III Tumor/Infection Imaging S $1,188.28 23 0414 Level II Tumor/Infection Imaging S $706.45 24

Issues Identified

• Anecdotal hospital medical practice shifts driven by

cost of the Dx RP and HOPPS APC packaged policy • Decisions on performing PET for FUO (fever of unknown origin), rather than white

blood cell (WBC) studies, are being made because of APC cost structure.

• Patients are traveling greater distances for studies as smaller hospitals have stopped

performing services that would be at a large cost loss to the hospital.

• Consolidation or industry exiting nuclear medicine field

• Some Dx RPs (radiopharmaceuticals) are now single sourced

• – e.g., Technetium MAA, DTPA, Xenon

• Increased costs are not current in CMS HOPPS data due to a two to three

year lag

25

SNMMI Meet with CMS

February 2015

The SNMMI is greatly concerned for our patients as some

hospitals have stopped performing services and they are

forced to go elsewhere for their testing. We are also

concerned for innovation and sustained products as we

have seen companies such as Bayer, Siemens, GE Healthcare

(new oncology tracers,) and GlaxoSmithKline (Bexxar) exit or

reduce participation in the nuclear medicine

radiopharmaceutical market in recent years.

26

See letter sent to CMS as follow up to February 2015 meeting for details.

SNMMI Proposal CY 2016

Simulation 2014 P HOPPS Data

Nuclear Medicine Procedures

# SNMMI Procedure Group Title SI Simulation CY 2016 FR GM

Packaged RP GM 2014

Data

RP Groups at

$100 dollar Threshold

1 Level 1 Nuclear Cardiology Dx Imaging S $400.11 $397.15

2 Level 2 Nuclear Cardiology Dx Imaging S $1,188.67 $1,037.02

3 Level 1 Nuclear Medicine Dx Imaging (planar, limited etc) S $346.98 $304.21 4 Level 2 Nuclear Medicine Dx Imaging (More complex) S $361.88 $350.12

5 Level 3 Nuclear Medicine Dx Imaging (SPECT, WB, multiple) S $515.95 $397.16 6 Level 4 Nuclear Medicine Dx Imaging (SPECT, two day) S $1,181.30 $541.37 7 Nuclear Medicine Dx Non-Imaging S $248.20 $226.83

8 Nuclear Medicine Dx PET (All Pet, Cardiac and Oncology) S $1,366.67 $1,140.59

9 Radionuclide Therapy (All NM Therapy) S $286.57 $278.83

Dx = Diagnostic

GM= Geometric Mean

FR = Final Rule 27

SNMMI Proposal CY 2016

Nuclear Medicine Dx Rp Grouped APCs

# SNMMI Procedure Group Title

20 RPs remain packaged as under $95 Threshold

SI Simulation CY 2015 FR 2013 Mean Unit x

Average unit per day

Weighted Average

Sample Dx RPs in the

Rps APC Group

1 Level 1 Dx Radiopharmaceutical $95.00 to $200 S $146.17 A9505, A9504, A9500, A9502,

A9528, A9580, A9562, A9556,

A9554, A9551

2 Level 2 Dx Radiopharmaceutical $200.01.00 to $400.00 S $226.76 A9552, A9521, C1204/A9520,

A9526, A9532, A4642,A9553+

3 Level 3 Dx Radiopharmaceutical $400.01 to $800.00 S $498.66 A9555, A9557, A9569, A9508,

A9570, A9548, A9521, A9547

4 Level 4 Dx Radiopharmaceutical $800.01 to $1,200.00 S $951.23 A9542, A9544

5 Level 5 Dx Radiopharmaceutical $1,200.01 to $1,600.00 S $1,396.27 A9507 A9582 (asp avail),

A9572

6 Level 6 Dx Radiopharmaceutical $1,600.01 to $2,000.00 S None this year

7 Level 7 Dx Radiopharmaceutical $2,000.01 to $2,400.00 S $2,380.64 A9584 DatScan

8 Level 8 Dx Radiopharmaceutical $2,400.01 to $2,800.00 S $2,696.00 A9582 I-123 MIBG &

A9568 B-Amyloid

9 Level 9 Dx Radiopharmaceutical $2,800.01 to $3,200.00 S None this year

10 Level 10 Dx Radiopharmaceutical $3,200.01 to greater S None this year

Consider new SI for RPs that would remove offset to eliminate duplicate payment of RP. 28

CY 2016 CMS - Nuclear Medicine

Proposed APC Restructure

# CY 2016

APC

CMS Group Title SI Payment Rate

1 5591 Level 1 Nuclear Medicine & Related Services (CPTs 78071, 78195, 78206 liver SPECT and flow, 78264 & new GES codes, GBP studies)

S $336.75

2 5592 Level 2 Nuclear Medicine & Related Services (CPTs 75563, MRI.SPECT MPI single, adrenal , parathyroid SPECT/CT, PET limited, blood volume)

S $473.78

3 5593 Level 3 Nuclear Medicine & Related Services (CPTs SPECT MPI multiple, PET most, T codes, 3D brain SPECT, tumor WB, CSF study)

S $1,172.71

4 5661 Non-Imaging Nuclear Medicine (CPTs 38792, all therapy, 78999, Vit B, platelet survival, 78808, 78725)

S $254.47

5 5523 Level 3 X-Ray & Related Services (CPT 78445 vas flow)

S $199.70

6 5524 Level 4 X-Ray & Related Services (CPTs 78457-78458 Venous Thrombosis)

S $363.21

7 5525 Level 5 X-Ray & Related Services (CPTs 78456 Acute Venous Thrombosis)

S $666.94

29

HOPPS CY 2016 PET vs non PET

Simulation of Split for APC 5593

APC APC

Description

CMS

Singles

CMS Geo

Mean

WPA

Singles

WPA Geo

Mean

Simulation

Singles

Simulation

Geo Mean

5593 Level 3

NM

858,777 $1,238.90 860,244 $1,240.69 860,244 $1,240.69

5593A NM & Related non PET Level 3 split (0331T, 0332T,

78451, 78452, 78454, 78607, 78647, 78804)

599,138 $1,189.41

5593B NM PET Imaging Level 3 split (78459, 78491, 78492,

78608, 78811, 78812, 78813, 78814, 78815, 78816)

261,210 $1,366.67

30

Federal Register Vol. 70 No 141

page 42723 (July 23, 2014)

CMS States, “Notwithstanding our commitment to package as

many costs as possible, we are aware that packaging

payments for certain drugs, biologicals, and

radiopharmaceuticals, especially those that are particularly

expensive or rarely used, might result in insufficient payments

to hospitals, which could adversely affect beneficiary access to

medically necessary services.”

31

The SNMMI presented examples to CMS and the HOP panel.

SNMMI Proposal to CMS

CY 2017

• The SNMMI requested that CMS

reconsider and propose for public

comment period to implement APCs for

groups of diagnostic

radiopharmaceuticals that will be paid

separately from the nuclear medicine APC

procedure groups for CY 2017.

32

Consequences of CMS not

adopting the SNMMI proposal

• Burden to beneficiaries who are traveling to the

decreasing number of facilities that are performing

the low volume high cost NM services.

• Stifles innovation and expansion in the NM

community as costs for new diagnostic RPs are not

covered after pass-through ends.

33

SNMMI Recommendations to

HOPPS Panel August 2015

The SNMMI recommends the HOP Panel request that CMS:

• Develop diagnostic radiopharmaceutical APC groups

• Adopt the SNMMI proposal for 8 diagnostic NM procedure

APCs specifically: • Maintain distinct APC for all PET procedures (currently APC 0308)

• Maintain distinct APC for therapeutic nuclear medicine procedures

(currently APC 0407)

• Create a new non-imaging NM APC Group consistent with resources

• Create four new Levels of Nuclear Medicine APC procedure groups that

build on the resource consumption and time for the various nuclear

medicine services, such as Planar, Multiple imaging, Multiple Studies,

Multiple day services, and SPECT and SPECT/CT studies.

• Maintain two Nuclear Cardiology APC groups

34

APC HOP Panel and CMS

Questions to SNMMI

• What evidence do we have to prove that

bundling is affecting volume of services?

• What evidence do we have that patient

access is being shifted to other sites or

other imaging studies, due to hospitals

deciding, only on tracer costs, to stop

providing?

35

2016 - Nuclear Medicine Payment Rates

CMS HOPPS APC Restructure

# 2016

APC

CMS Group Title SI Payment

Rate 2016 1 5591 Level 1 Nuclear Medicine & Related Services

(CPTs 78070-1, 38792, 78195, 78206 liver SPECT / flow, 78264, 78265, GBP studies,

Vit- B, 78808, 78445, 78458 bilateral venous thrombosis, 78999)

S $332.65

2 5592 Level 2 Nuclear Medicine & Related Services (CPTs, MRI 75559.SPECT MPI single, parathyroid SPECT/CT, PET limited, blood

volume, 78457 venous thrombosis)

S $441.36

3 5593 Level 3 Nuclear Medicine & Related Services (CPTs 75563, 78451-2, 78456, acute venous thrombosis, adrenal 78075, Plat

Survival 78191,T codes, brain SPECT, tumor WB, CSF study)

S $1,108.46

4 5594 Level 4 Nuclear Medicine & Related Services (CPTs all PET, CMS reserves the right to put non pet in this APC in the future.)

S $1,285.17

5 5661 Non-Imaging Nuclear Medicine

(CPTs all therapy, 78725)

S $249.98

36

APC rates will vary geographically. Figures used are not actual hospital payment rates.

CPT ® is a registered trademark of the American Medical Association

SNMMI Coding and

Reimbursement Activities

• SNMMI Coding & Reimbursement Committee

• CPT Advisors to AMA CPT Editorial Panel

• RUC Advisors to AMA Relative Value Update Committee (RUC)

• Answers members direct questions

• Collaborate w/ industry for new & established NM studies

• SNMMI Coding Education

• Chapter meetings and Webinars, Assist NOPR & IDEAS

• SNMMI Coding Corner –Updates and Q&As

• Industry Forum and Legislative Activities

37

Industry Forum Initiative: Data Collection to Support a

Legislative Approach to APC Reform

Situation:

• CMS does not recognize negative impact in

utilization resulting from bundling policy (claims

data do not reflect major shifts after pass-through,

new RP’s have no claims trends)

• Slow uptake of new RP’s is potentially creating

access issues for Medicare beneficiaries

• Direct evidence on impact of new technology

adoption and patient access issues from

providers most desirable

Objective:

• Obtain direct provider feedback to determine extent

of impact of payment methodology

Industry Forum Initiative: Data Collection to Support a

Legislative Approach to APC Reform

Method:

• Robust independent survey instrument with

decision-makers in NM and Radiology

Considerations:

• Question logic and balance, geographic and

provider diversity, proper size and scope

• Evidence must be credible and compelling, and

meet the differing needs of both CMS and

Congress

Status:

• RFP’s have been initiated with qualified vendors

Next Step

40

• More to come.