October 2, 2019
Thank you to all the SNMMI members who sent messages to Congress and comments to the Centers for Medicare and Medicaid Services (CMS) about its proposal to reduce reimbursement by up to 80 percent for myocardial PET in the office setting. Your efforts helped the society and peer groups secure signatures from 43 members of Congress on the Congressional letter led by Ron Kind (D-WI), Mike Kelly (R-PA), and Ronald Estes (R-KS) asking CMS to address the cuts. This letter will help amplify the very real concerns of clinicians and patients about access to critical cardiovascular care.
Additionally, your engagement on our Call to Action resulted in CMS receiving more than 40,000 public comments on the proposed 2020 Medicare Physician Fee Schedule! We asked for your help, and you acted swiftly to ensure CMS hears the cost of making cardiac PET accessible to patients.
Many thanks also to those members who provided additional invoices, which we included in our submissions as a summary table and supplemental materials. These items helped the society convey to CMS that major reductions in Medicare reimbursement for cardiac PET will greatly disadvantage patients and will reduce interest in discovering new applications of this important technology.
SNMMI engaged with the American College of Cardiology (ACC), the American Society of Nuclear Cardiology (ASNC), the American College of Nuclear Medicine (ACNM), and the Cardiology Advocacy Alliance (CAA) to address the cuts, which were included in the proposed 2020 Medicare Physician Fee Schedule (MPFS). The revisions result from updates to the current procedural terminology (CPT) codes used to report these services and review of the direct practice expense inputs that inform the calculation for the technical component payment.
SNMMI and ACNM submitted comments to CMS on the proposed rule recommending corrections in the way that CMS calculates the inputs and accepts invoices for use in the payment formula for the new CPT codes for nuclear medicine and molecular imaging procedures, specifically for CY 2020 myocardial PET and SPECT and SPECT-CT procedures. In this letter SNMMI and ACNM recommended that CMS should consider utilizing the most recent contractor priced claims data (2018) for paid claims for CPT 78459, 78491 and 78492 (utilizing a weighted average) in the physician office and IDTF setting that would stabilize a payment for CY 2020. This approach would keep payment rates stable in 2020 and allow stakeholders the opportunity to provide CMS additional information on equipment costs.
CMS will consider these and other comments received by the September 27 deadline and decide whether to finalize cardiac PET rates as proposed or adopt an alternative payment policy. A final rule is expected on or around November 1. SNMMI will keep members informed and evaluate next steps when the rule is released.
Vasken Dilsizian, MD