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SNMMI Submits Comments to CMS Regarding CY 2016 Final Rules for HOPPS and MPFS

December 16, 2015

On Wednesday, December 16, SNMMI submitted comments to CMS on the CY 2016 Final Rules for the Hospital Outpatient Prospective Payment System (HOPPS) and the Medicare Physician Fee Schedule (MPFS). 

In the HOPPS letter, SNMMI commented on APC restructuring for nuclear medicine services, OPPS treatment of new CPT and Level II HCPCS codes, Off‐Campus Provider‐Based Departments, CMS Offset File, and Q9969 Code. As you know, SNMMI met with CMS earlier this year regarding APC restructuring. Unfortunately, SNMMI's recommendations were not included in the Final rule. Members should consider providing CMS with comments on this important issue. The deadline to submit comments is no later than 5:00 p.m. ET on December 29. Comments can be submitted at

In the MPFS letter, SNMMI commented on CY 2016 identification of potentially misvalued services, colon transit imaging, and Appropriate Use Criteria. SNMMI supports CMS’ decision to delay the AUC provision and adopt policies regarding claims-based reporting requirements in the CY 2017 and CY 2018 rulemaking cycles.