MITA Submits Comments in Response to CMS Medicare Hospital Outpatient Prospective Payment System Proposed Rule

Sep 16, 2022, 08:58 AM

Washington, D.C. – The Medical Imaging & Technology Alliance (MITA) – the leading trade association representing manufacturers of medical imaging equipment, radiopharmaceuticals, contrast media, and focused ultrasound therapeutic devices – has submitted comments to the Centers for Medicare and Medicaid Services (CMS) responding to the Agency’s 2023 Medicare Hospital Outpatient Prospective Payment System (HOPPS) and Ambulatory Surgical Center Payment System Proposed Rule.

“Across the board, we’ve seen how payment policies directly impact the ability of patients to access medical imaging innovations,” said Patrick Hope, executive director of MITA. “Whether it’s ensuring appropriate reimbursement for diagnostic radiopharmaceuticals or making sure adoption of cutting-edge AI innovations is adequately incentivized, we appreciate the opportunity to comment on the many payment policies included in this proposed rule.”

In its comments, MITA expressed support for measures that would expand access to imaging innovations by establishing separate payment for certain diagnostic radiopharmaceuticals and encouraging development of policies that accurately capture the cost of adopting and providing artificial intelligence (AI)-enabled services that are aligned with appropriate reimbursement policies.

The letter also expressed concern about the impact on providers of the proposed decrease to the HOPPS conversation factor. MITA also recommended extension of pass-through status for products affected by the COVID-19 pandemic and commented on payment codes for ablation of prostate tissue, Fractional Flow Reserve derived from Computed Tomography (FFRct), and certain breast imaging localization Current Procedural Terminology (CPT) codes. The letter also raised concern with CMS’ proposal to remove the $10 add-on payment for non-highly enriched uranium (HEU) radiopharmaceuticals.

To read MITA’s full comments, click here.


The Medical Imaging & Technology Alliance (MITA), a division of NEMA, is the collective voice of medical imaging equipment manufacturers, innovators, and product developers. It represents companies whose sales comprise more than 90 percent of the global market for advanced medical imaging technology. For more information, visit Follow MITA on Twitter @MITAToday.