Washington, D.C. – The Medical Imaging & Technology Alliance (MITA), the leading organization and collective voice of medical imaging and radiopharmaceutical manufacturers, innovators, and product developers, today submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to proposed rules on the Physician Fee Schedule (PFS) and the Hospital Outpatient Prospective Payment System (HOPPS).

In its proposed HOPPS rule, CMS requested input from the community on how HOPPS packaging policy for diagnostic radiopharmaceuticals has impacted beneficiary access. MITA has long advocated for ending the policy packaging for diagnostic radiopharmaceuticals. Citing reduced patient access to such products, Patrick Hope, Executive Director of MITA, said,“ MITA strongly supports establishing separate payment based on Average Sales Price (ASP) methodology for diagnostic radiopharmaceuticals in the CY 2024 Final Rule. MITA urges CMS to make such a change in the final rule, as there is sufficient evidence presented by MITA and others to make this long-overdue change immediately.”

In addition to addressing separate payment, among other things, the letter also provided comments on:

• Adoption of a measure on excessive radiation dose or inadequate image quality for diagnostic computed tomography (CT) in adults;
• Add-on payment for highly-enriched uranium radiopharmaceuticals;
• Software as a service (SaaS) procedures;
• Finalizing a proposal to assign Fractional Flow Reserve derived from CT; and
• Revisions for payment indicator breast localization codes.

In a separate comment to the proposed HOPPS, MITA said CMS’s remedy to its payment policy for 340B-acquired drugs from 2018-2022, per the District Court’s order, would impose “another automatic 0.5% payment reduction on HOPPS services for the next 16 years, in addition to the 2.0% sequestration reduction now reinstated post the Public Health Emergency (PHE). These cuts would come at a time when hospitals continue to struggle to regain the volume of outpatient services provided, including medical imaging services, prior to the pandemic.

In comments to the proposed PFS, MITA expressed concern for proposed deep cuts to physician payments, that, if not reversed, will result in a three percent payment cut to radiology, a three percent cut to nuclear medicine, and a four percent cut to interventional radiology.

In its letter, MITA said the consistent downward pressure on physician payment will result in significant challenges for beneficiary access and the ongoing viability of physician practices.

Beyond urging CMS to fix physician reimbursements, MITA applauded CMS policy methodology to reimburse providers using artificial intelligence, algorithms, and other software based on cost and matching with an appropriate APC code.

To read MITA’s full HOPPS comment letter, click here.

To read MITA’s HOPPS 340B remedy comment letter, click here.

To read MITA’s full PFS comment letter, click here.

 

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