SNMMI Submits Comments to CMS for CY2015 HOPPS & MPFS Final Rules

January 6, 2015

SNMMI recently submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding the Calendar Year (CY) 2015 Final Rules for the Hospital Outpatient Prospective Payment System (HOPPS) and the Medicare Physician Fee Schedule (MPFS). Both rules were due no later than 5pm ET on Wednesday, December 31, 2014.

On Friday, December 19, SNMMI submitted comments to CMS regarding the CY15 HOPPS Final Rule.

  • SNMMI continues to have concerns with expanded packaging and is disappointed that CMS did not provide impact tables by specialty, APC or CPT codes. SNMMI asks CMS to conduct additional analysis in the CY16 Rule to better understand the impact and ensure Medicare beneficiaries’ access is not negatively impacted by increased packaging.
  • SNMMI appreciated that CMS made the reporting period for off-campus provider‐based departments voluntary for one year, but we remained concerned that it will be mandatory after January 1, 2016.
  • SNMMI remains concerned with individual APC placements for a variety of nuclear medicine procedures and services. While CMS did not accept any of the line item services for parathyroid or therapy services in the final rule, SNMMI continues to have global concerns regarding the APC structure as a whole. We plan to meet with CMS in the future in regard to the CY 2016 Rules with some potential new APC structures.
  • CMS continues to provide off-set files only with the final rule, therefore providing comments can only occur after these files are released rather than during the open comment period following the proposed rule. SNMMI remains concerned with the format and implementation of these off-set files as CMS. SNMMI respectfully recommends that CMS create an offset file separating the diagnostic radiopharmaceuticals from the contrast and stress agents and any skin substitutes.

On Tuesday, December 23, SNMMI submitted comments to CMS regarding the CY15 MPFS Final Rule.

  • SNMMI appreciates CMS’s efforts to work on the administrative aspects of the SGR as well as their continued work to monitor Congress and implement any possible fixes quickly.
  • SNMMI would like to thank CMS for acknowledging public comments regarding the HCPCS modifier for off-campus provider‐based departments. CMS has decided to delete the current POS code 22 rather than finalize a HCPCS modifier in the CY 2015 MPFS Final Rule.
  • SNMMI is disappointed that CMS did not implement the American Medical Association’s (AMA) proposed timeline for establishing the values for new, revised and potentially misvalued codes and requests that CMS reconsider the timeline revisions in the CY16 MPFS Rule.
  • Regarding the Physician Quality Reporting System (PQRS), SNMMI requested that CMS provide specialty organizations with support to develop meaningful measures, recognize prevailing quality improvement endeavors such as laboratory accreditation, continue providing a mechanism to avoid payment adjustments, and provide information on the program’s tiering calculation as it relates to the cost composite score.