Will Congress Stop Medicare Cuts?

Radiologists find themselves once again in a familiar position, facing CMS cuts in Medicare and Medicaid physician payments for 2025. A new analysis by revenue cycle management company Healthcare Administrative Partners details the impact of the reductions, as well as other reimbursement changes set to take effect next year. 

CMS has been driving down radiology reimbursement for years, a trend widely seen as part of the agency’s effort to shift funding from medical specialties to primary care. 

  • That’s having an impact on physician pay, as a study last week found that private-practice diagnostic radiologists have seen inflation-adjusted salaries decline at a -1% annual rate since 2014. 

That trend is set to continue in 2025, with CMS publishing its final rule for the Medicare Physician Fee Schedule that affirms most of the changes it proposed in July. In the new article, HAP’s Sandy Coffta unpacks the changes, which include … 

  • A new conversion factor of $32.3465 (down from $33.2875).
  • Payment reductions of -2.8% for radiology and nuclear medicine, and -4.8% for interventional radiology.

But not all of the changes are negative. Other 2025 policies that affect radiology include …

  • Reimbursement for CT colonography for Medicare beneficiaries at a rate of $108.68 for the professional component.
  • New codes for reporting MRI safety procedures.
  • New quality category measures in the Merit-based Incentive Payment System.

CMS proposed similar cuts last year, but Congress swooped in at the last minute to roll them back with the Consolidated Appropriations Act, which applied a positive 2.93% upward adjustment. 

  • Several bills in Congress now would likewise stave off the 2025 reductions (H.R. 2474 and H.R. 10073), but time is running out to pass them before the current Congressional session expires on January 3, 2025. 

The Takeaway

Will Congress once again ride to the rescue and stave off Medicare reimbursement cuts, as it did a year ago? Or will things be different this time, given the political turbulence that’s shaking Washington, DC? We’ll find out in a few weeks.

Unpacking 2025 Medicare Changes

Here we go again. CMS has once again proposed cuts in Medicare and Medicaid reimbursement, and the healthcare community is once again rallying to try to stave them off. 

CMS last month released its proposed reimbursement changes for 2025, and there were a few victories for radiology. 

  • CMS finally agreed to pay for CT colonography, and also agreed to unbundle payments for PET radiotracers from the PET scan itself.

But CMS also proposed changes in the Medicare Physician Fee Schedule (MPFS) conversion factor that continue the slow drip of reimbursement reduction for physicians.

  • The agency said the proposal would result in no change for radiology, but a deeper dive reveals that’s not the case. 

For example, the analysts at revenue cycle management firm Healthcare Administrative Partners have reviewed the MPFS changes, calculating that if Congressional adjustments are factored in, the outlook is quite different…

  • Interventional radiology will see a -5.8% reduction in the imaging center global fee and a -1.8% drop in the hospital professional fee, for a combined decline of -4.8%
  • The numbers for radiology and nuclear medicine are -3.8% for imaging centers and -1.8% for hospitals, for combined declines of -2.8%

It may seem like -2.8% isn’t a huge cut, but it continues years of steady declines in Medicare reimbursement (HAP notes that the Medicare physician fee schedule has dropped -10% in the last 10 years).

  • And as anyone in healthcare knows, the costs that healthcare practices face have only gone up over that period.  

There’s always the chance that Congress will come to the rescue, as it did when it passed the Consolidated Appropriations Act of 2024 – indeed, professional medical groups led by the AMA published a letter last week urging lawmakers to reform CMS’ rate-setting system in several ways …

  • Enact an annual payment update tied to inflation
  • Eliminate the requirement that changes in payments be budget-neutral
  • Overhaul the Merit-based Incentive Payment System (MIPS)
  • Make modifications to Alternative Payment Models

The Takeaway

The annual ritual in which CMS proposes sharp cuts in Medicare reimbursement only to have Congress lift them at the last minute is a sort of public policy kabuki dance in which the outcome is practically preordained. Medicare reform is badly needed to end this cycle and put physicians on firmer footing so they can focus on what’s important: caring for patients.

Doctors Work Harder for Less

Medicare reimbursement to physicians per beneficiary has declined over the last 16 years, with radiologists among the biggest losers. That’s according to a new study by the ACR’s Harvey L. Neiman Health Policy Institute, which confirms what many physicians already knew: they are working harder for less money.

It’s no secret that the US government has been struggling to rein in healthcare costs for decades. 

CMS has a number of tools at its disposal for controlling Medicare and Medicaid costs, one of which is the relative value unit (RVU) scale. 

  • RVUs – when multiplied by monetary conversion factors – basically set the amount of money the agency pays physicians per unit of work, with CMS typically reducing the conversion factor when it needs to cut Medicare spending. 

In the new study in the journal Inquiry, Neiman HPI researchers analyzed trends in RVU and conversion factor levels per Medicare beneficiary from 2005 to 2021, analyzing changes to calculate how much work providers have to do to deliver a unit of care. Findings included …

  • Reimbursement per Medicare beneficiary after inflation adjustment fell 2.3% for physicians as a whole
  • Radiology saw one of the biggest declines in MPFS reimbursement per beneficiary, ranking 31st on a list of 39 medical specialties, with a 25% decrease
  • Reimbursement has risen 207% for non-physician practitioners

What’s driving the declines? The Neiman HPI researchers identified the federal government’s budget neutrality rules for Medicare, which stipulate that increases in one area have to be offset by declines elsewhere.

The Takeaway

The new findings confirm what many physicians have suspected – they are not only working harder for less, but non-physician practitioners seem to be getting a bigger piece of the pie. Combined with a recent report showing that radiologist salaries didn’t keep pace with inflation in 2023, it’s not a pretty picture. 

Is Head CT Overused in the ED?

A new study suggests that head CT could be overused in the emergency department for patients presenting with conditions like headache and dizziness. Writing in a paper in Internal and Emergency Medicine, researchers looking at CT angiography use at a large medical center found a big increase in CTA utilization – even as the rate of positive findings dropped. 

CTA is a powerful tool that can quickly and efficiently give clinicians information to guide treatment of acute neurovascular conditions like aneurysm and stroke. 

  • As such, many emergency departments have been installing their own CT scanners to enable them to scan emergent patients without transporting them to the radiology department. 

But with great power comes great responsibility, and there is always the temptation to scan first and ask questions later. 

  • To better understand changing CTA use in the emergency setting, researchers from the Harvey L. Neiman Health Policy Institute analyzed CTA exams at a level 1 trauma center that sees about 110k emergency patients a year.

Researchers analyzed 25k ED visits from 2017 to 2021 and correlated them to head and neck CTA exams for headache and/or dizziness, finding …

  • The rate of CTA exams rose 64%, from 7.9% of ED visits to 13%
  • Symptomatic patients were 15% more likely to have a CTA in 2021 versus 2017
  • The rate of positive CTA findings fell 38%, from 17% to 10%
  • Patients with private insurance were more likely to have CTA (OR=1.44)
  • Black patients were less likely to be scanned (OR=0.69)

The researchers said the findings indicate the need for better clinical decision support tools, which they believe can help emergency physicians provide an accurate diagnosis without exposing patients to unnecessary radiation and incurring additional cost. 

The Takeaway

This study further confirms widespread accounts that head and neck CTA is overused and on the rise. As the US government backs off on its attempt to force clinical decision support on referring physicians, it may be up to health systems and providers themselves to ensure more appropriate utilization – in a way that doesn’t rely on heavy-handed tools like prior authorization. 

Imaging and US Healthcare Costs

In the debate over rising US healthcare costs, medical imaging is often painted as a bad guy. But a new study in Health Affairs Scholar claims that since 2010, spending on imaging services has not grown at the same rate as other medical services. 

It’s no secret that the US spends far more on healthcare per capita than other developed countries, spending 16.6% of GDP as of 2022 according to OECD data. 

  • For point of reference, Germany spends 12.7%, France spends 12.1%, and most other developed countries spend under 12% of GDP. 

Reasons why the US is such an outlier have been blamed on a variety of factors, such as pharmaceutical prices, physician salaries, administrative costs, and the fragmented nature of the US healthcare system. 

  • But medical imaging is often singled out for criticism, perhaps due to the high cost of scanners and the explosion of imaging volume since the advent of cross-sectional technologies like CT and MRI in the 1970s and 1980s. 

This has led the US government to exert major pressure on imaging reimbursement in the Medicare and Medicaid systems, starting with the Deficit Reduction Act of 2005 and continuing to the present day, while private insurers have employed tools like prior authorization. 

The new study indicates that these efforts may have accomplished their mission. Researchers from the ACR’s Harvey L. Neiman Health Policy Institute analyzed imaging’s contribution to overall growth of medical costs from 2010 to 2021 in employer-sponsored insurance plans, finding …

  • Spending on medical imaging grew 36% 
  • Spending for all other healthcare services grew 64% 
  • Two-thirds of the growth in imaging spending was due to general price inflation
  • Only one-fifth was due to increased utilization
  • Imaging’s share of total US healthcare spending fell from 10.5% to 8.9%

The findings indicate that efforts by the US government and private payors to drive down imaging utilization are working … but at the price of overworked radiology staff.

  • Imaging cuts could also be leading to patient access issues, as the study found that the percentage of patients undergoing imaging fell from 46% in 2010 to 40% in 2021. 

The Takeaway

The new study reinforces what imaging advocates have been saying for years – that medical imaging isn’t a major cause for runaway healthcare spending in the US. The question is whether anyone outside of radiology is listening.

Medical Malpractice Crisis

Is a new crisis looming in medical malpractice insurance? An AMA analysis finds that medical liability premiums are skyrocketing again – and radiologists may be among the physicians most affected due to their higher exposure to malpractice suits.

The proportion of medical liability premiums that increased year-to-year for OB/GYN, general surgery, and internal medicine doctors (radiologists weren’t surveyed) doubled from 2018 to 2019 (13.7% to 26.5%), and went up 30% year-to-year from 2020 to 2022. The last time rates rose this fast was during the medical liability crisis of the early 2000s, according to the AMA paper.

Insurers are raising premiums due to deteriorating underwriting results, lower loss reserve margins, and lower returns on investment, per the report. These trends are echoed in a new analysis of the medical malpractice segment by credit agency AM Best, which describes a “difficult environment” for medical liability insurers. The medical professional liability segment has seen eight straight years of underwriting losses.

Why should radiologists care? Well, radiologists are more likely to have experienced medical liability claims during their career than most other physicians. Another AMA survey of over 6k doctors found

  • Radiologists were more likely to say they had been sued in their career than all physician types (40.2% vs. 32.1%)
  • More radiologists have experienced a lawsuit in the past year than all physicians (4.2% vs. 2.0%)
  • The only other medical specialists more likely to be sued than radiologists were surgeons (48.9%) and emergency medicine physicians (46.8%) 

The first AMA report closes by saying that a medical liability insurance “hard” market – a market characterized by rapid price increases – already exists in a number of states, and is “slowly spreading” across the rest of the US. 

Further, there is “striking” geographic variation in premiums. OB/GYNs in Los Angeles County, California see average manual premiums of $49,804 a year, while those in Miami-Dade County, Florida are staring at a $226,224 liability insurance bill.

The Takeaway 

The AMA said the growing medical malpractice crisis could have multiple ramifications. Physicians in states with difficult liability environments could relocate or even drop some clinical services that raise their risk. Will the worsening environment draw the attention of state and federal regulators? Only time will tell. 

ACR Grants NPPs’ Contrast Supervision

The American College of Radiology (ACR) rolled out a significant change to its imaging contrast guidelines, allowing non-radiologists and non-physician practitioners (NPPs) to supervise intravenous CT and MRI contrast administration at accredited imaging centers.

A range of NPPs (NPs, PAs, RNs) and qualifying non-radiologist physicians will be able to directly supervise contrast administration under the “general supervision” of on-site radiologists, as long as it’s supported by state scope of practice laws. 

  • Superving radiologists must be available for “assistance or direction” and trained to handle acute contrast reactions/situations, but they won’t have to be in the same room as the patient.

These guidelines mirror the ACR’s new practice parameters for contrast supervision (adopted in May), and follow CMS’ recent efforts to expand more diagnostic tasks to non-physicians.

  • CMS granted radiology assistants the ability perform a range of imaging tasks in 2020 and permitted NPPs to directly supervise Level 2 tests in 2021 (like contrast-enhanced CT and MRI), in both cases requiring “general” radiologist supervision (on-site, but not in room… and virtual during the pandemic).

Although NPPs’ radiology expansion has historically sparked heated debates, the new ACR contrast supervision guidelines hasn’t faced many public objections so far. 

  • That’s potentially because some (busy) radiologists don’t view directly supervising contrast administration as a practical or efficient use of their time (even if they still have to drive to the imaging center), especially considering that technologists often spot adverse reactions before anyone else.
  • However, there’s surely plenty of radiologists who are concerned about whether these new guidelines might exacerbate scope creep, cut their earning potential (especially trainees), reduce radiologists’ patient-facing opportunities, and undermine patient care.

The Takeaway

The ACR’s decision to grant NPPs greater contrast supervision rights and loosen radiologists’ contrast supervision requirements might not be surprising to folks paying attention to recent ACR and CMS policies. That said, it’s still a notable step (and potential contributor) in the NPPs’ expanding role within radiology – and opinions might differ regarding whether that’s a good thing.

The MARCA Divide

The American College of Radiology might have a neutral stance on the Medicare Access to Radiology Care Act (MARCA), but a new survey confirmed that most ACR members are far from neutral about non-physicians’ role in radiology. 

MARCA Madness – MARCA would require Medicare to reimburse supervising radiologists for imaging services performed by radiologist assistants, as long as RAs work within physician-led teams. The ACR revealed its neutral position on MARCA in August, enraging some members who are concerned that MARCA will undermine radiologists’ role, and accused the ACR of selling out to PE. 

The Opinion Divide – The ACR survey (n = 4,207, or 16% of members) revealed overwhelming opposition to MARCA, but more balanced views on working with non-physician radiology providers (NPRPs). By NPRPs, they mean radiology assistants, advanced practice registered nurses, and physician assistants.

  • 60% are against MARCA (vs. 19% in favor, 21% neutral)
  • 86% are concerned about NPRP scope creep
  • 55% view NPRPs as a threat to patient care
  • However, just 43% are against using NPRPs in their practice
  • And 62% believe it’s up to practices whether they employ NPRPs

Behind the Divide – A deeper look into the ACR’s (very detailed) survey results revealed that members’ MARCA and NPRP opinions seem largely influenced by their professional situation. 

Career Stage

  • 80% of residents/fellows and 65% of early-career rads view NPRPs as a threat to patient care 
  • 51% of mid-career rads and 41% of late-career rads view NPRPs as a threat to patient care

Practice Type

  • 61% of respondents from academic settings view NPRPs as a threat to patient care
  • 69% of respondents from national and private practices think NPRP use is a practice decision 

Practice Role

  • 61% of non-leaders view NPRPs as a threat to patient care
  • 65% of practices leaders view NPRPs use as a practice decision

NPRP Experience

  • 69% of respondents who do not work with NPRPs view them as a threat to patient care
  • 57% of respondents who work with NPRPs believe they play an important role
  • 84% of respondents who support MARCA currently work with NPRPs

The Takeaway – We now have data confirming what most of you already knew: the majority of radiologists are firmly against MARCA and a small minority support it. However, the data also shows that plenty of radiologists see value in NPRPs, especially if they already work with non-physicians and if their careers are less threatened by them. What’s still unclear is what it will take for the ACR to break its neutrality on MARCA (in either direction).

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