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For Immediate Release
September 14, 2007
Contact:
Kathryn Coulter, 202-419-3257
MITA Comments on Proposed CMS Rule Altering Payment Rates
of the Hospital Outpatient Prospective Payment System [HOPPS]
and the Ambulatory Surgical Center Payment System
Arlington VA - The Medical Imaging and Technology Alliance (MITA), a division of the National Electrical Manufacturer's Association (NEMA), today submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to the recently released "Proposed Changes to the Hospital Outpatient Prospective Payment System and CY 2008 Payment Rates; Proposed Changes to the Ambulatory Surgical Center Payment System and CY 2008 Payment Rates."
In a letter to Acting CMS Administrator Kerry N. Weems, MITA Vice President Andrew Whitman noted, "MITA has accepted packaging of carefully selected ancillary services into those principal procedures with which they are always or nearly always performed. However, we have numerous concerns about the sheer scope and approach of the packaging policies outlined in the Proposed Rule." Among those concerns:
- CMS has not proposed adequate regulatory standards to guide and support the packaging proposals, nor sufficient information to properly evaluate them.
- The scope and breadth of the proposals could undermine the structural integrity of the Ambulatory Payment Classification (APC) system, and create hospital payment anomalies and impermissible savings relative to budget neutrality requirements.
Within the comments, MITA made the following recommendations:
- Delay the packaging proposals for at least one year, and in the interim effectively develop and communicate the principles and regulatory (clinical relationship, payment decision, and exceptions) standards likely to govern packaging approaches.
- Treat all radiopharmaceuticals, including contrast agents, as drugs entitled to separate payment and not subject to packaging if their costs exceed the prevailing dollar packaging threshold.
- Provide pass-through payments for new technologies and refrain from premature clinical assignment or packaging of items or services that may be eligible for APC pass-through payments.
- Create a separate clinical APC that reflects all of the costs associated with PET/CT, allowing the CMS payment structure to more adequately reflect all the resources performed with PET/CT; and continue to pay separately for diagnostic radiopharmaceuticals as specified covered outpatient drugs.
- Reassign Coronary Computed Tomography (CCT) and Computed Tomographic Angiography (CTA) procedures to an appropriate New Technology APC for CY 2008 and continue to pay separately for contrast agents.
"While contemplating changes to Medicare payments for imaging services, CMS must look to the future as new developments in molecular, cellular, functional and genetic imaging promise a new era of prediction and prevention of disease, not just diagnosis and treatment. Imaging has the potential to save and improve the quality of life of millions of people, but only if made accessible to all in need," Whitman said.
To read the MITA comments letter in its entirety, please visit www.medicalimaging.org.
The Medical Imaging & Technology Alliance (MITA) is the leading medical imaging association, representing companies whose sales comprise over ninety percent of the global market for medical imaging equipment. These technologies include:
- Medical X-ray equipment
- Computed tomography (CT) scanners
- Nuclear imaging, including positron emission tomography (PET)
- Magnetic resonance imaging (MRI)
- Diagnostic ultrasound
- Radiation therapy equipment
- Imaging information systems
For more information on medical imaging, please visit www.medicalimaging.org
Medical Imaging & Technology Alliance, 1300 North 17th Street, Suite 1752, Arlington, VA 22209
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