August 20, 2003
I'm Ken McKusick, MD, a retired nuclear medicine physician formerly with Massachusetts General Hospital. I am here today on behalf of the Nuclear Medicine APC Task Force* which I have chaired since its inception 7 years ago. I appreciate the opportunity to be at today's meeting of the APC Advisory Panel.
Like you, I have only had a brief time to review the proposed 2004 HOPPS rule so my comments today will be very limited. CMS has reclassified many nuclear medicine procedures into APCs that are organ or system based. This division of nuclear medicine appears to be a violation of the fundamental premise of the APC system. This new model ignores the resources utilized in performing the procedures. For example, APC 401 includes 78587 Aerosol lung image, multiple and 78588 Perfusion lung imaging. 78587 involves a single radiopharmaceutical and a single set of images. In contrast, 78588 requires two radiopharmaceuticals and multiple sets of images. Based on resource utilization, there is no rational way that these two procedures can be in the same APC. This is true for all of the new nuclear medicine APCs
In short, the organ and system structure used in this proposed rule does not work. We ask the advisory panel to urge CMS to abandon this approach.
Last year, this panel supported our suggestion that CMS develop radiopharmaceutical APCs and work with the Nuclear Medicine APC Task Force on that concept. We met with them and made a proposal. CMS has not followed through on the Advisory Panel's recommendation or the Task Force's suggestions.
Currently many radiopharmaceuticals are bundled in to the APC procedure payment. CMS has made an attempt to recognize the difference in low and higher cost radiopharmaceuticals by providing for separate payment of some radiopharmaceuticals by setting a threshold of $150 per day. The bulk of the nuclear medicine APC payments range between $150 and $300. The threshold for separate payment is approximately 50% to 100% of the procedure reimbursement. We think that this is too high and recommend that the threshold should be set at $50.
We again ask this panel to recommend that CMS refine their descriptors used for radiopharmaceuticals, specifically, to describe the amount or quantity by the "unit dose" whenever possible rather than by uCi and mCi.
While I have focused on what we see as significant problems with this year's proposed rule, I do want to commend CMS for acknowledging that there are difficulties with the radiopharmaceutical data and directing that facilities list the HCPCS codes of radiopharmaceuticals used next year.
Thank you for your time.
* Nuclear Medicine APC Task Force