ASNC Comments on Physician and Hospital Outpatient Proposed Payment Policies; Casts Doubts about Stand-Alone AUC Program

On September 6, 2016 ASNC submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the CY2017 Medicare Physician Fee Schedule (MPFS) and the CY2017 Hospital Outpatient Prospective Payment System (OPPS). 

CY2017 Hospital Outpatient Prospective Payment System

ASNC’s OPPS comments offered feedback on the implementation of §603 of the Bipartisan Budget Act of 2015, the consolidation of Radiology/ Imaging Ambulatory Payment Classifications (nuclear medicine APCs were not restructured in this proposed rule), suggestions on the placement of CPT Code 78459 in the Level IV Nuclear Medicine APC, the proposed payment modifier for X-ray films and the continuation of the Q9969 Code which provides incentives for users of non-HEU sourced isotopes. 

View full text of the CY2017 OPPS comments  

CY2017 Medicare Physician Fee Schedule Comments 

ASNC comments for CY2017 focus on the implementation and operational requirements of the appropriate use criteria (AUC) mandate for advanced diagnostic imaging tests. The AUC consultation mandate will not begin before January 1, 2018, but rulemaking to implement the AUC program began last year. 
Members are encouraged to review our comments to CMS to understand some of the challenges nuclear cardiologists could face as implementation of the Medicare AUC Program nears. 

ASNC’s Health Policy Committee and other members of leadership have worked diligently over the past few months to develop new strategies for CMS to consider as it translates legislation into regulation. In its letter, ASNC provided detailed feedback on priority clinical areas, display of AUC in Clinical Decision Support Mechanisms (CDSMs), CDSM integration with EHRs, and claims and billing challenges.
 
View full text of the CY2017 MPFS comments