Nuclear Medicine APC Task Force and SNM Comment on Proposed CY 2006 HOPPS Payment Rates

On September 15, the Society of Nuclear Medicine and the Nuclear Medicine APC Task Force submitted comments to Mark McCellan, MD, PhD, administrator of the Centers for Medicare & Medicaid Services (CMS), on the proposed changes to the Hospital Outpatient Prospective Payment System.

Some of the highlights in both of these comments penned by Gary Dillehay, MD, chair of Coding & Reimbursement Committee and Kenneth A. McKusick, MD, chair, Nuclear Medicine APC Task Force, include:

• Requested CMS to consider the impact to the payment system and the burden to hospitals regarding significantly changing payment methods for radiopharmaceuticals from year to year.
  
  
• Strongly disagree with the CMS and MedPAC conclusion that hospitals accounted for all their costs directly or indirectly related to both the acquisition cost and handling fees for radiopharmaceuticals.
  
  
• Requested that CMS release an official, detailed definition of what providers should include in radiopharmaceutical charges to cover the recognized (MedPAC) high handling costs inherent to the use of radiopharmaceuticals.
  
  
• Strongly recommended that CMS work with medical specialty societies and industry to develop these "handling" categories, and only create categories if necessary [ed: for separate handling costs for radiopharmaceuticals]. If the CMS plans to use them moving forward to collect more data about handling costs, then we requested that the CMS set payment for each category to help deflect the additional cost to hospitals for this added burden and to ensure adequate data collection. In addition, we asked for concurrent direction to the hospitals about including the cost of handling into their charges for radiopharmaceuticals.
  
  
• Strongly encouraged CMS to use external data to adjust PET/CT payment rates.
  
  
• Support continued discussion with the CMS on the issue of appropriate payment for the technical costs of performing a diagnostic CT acquired simultaneously with a PET/CT.

The Nuclear Medicine APC Task Force will request a meeting with CMS to discuss payments for radiopharmaceuticals and handling fees in 2006.

In separate comments, the SNM addressed in more detail the issue of appropriate reimbursement for diagnostic CT when performed in conjunction with PET/CT and provided additional data and support for the Task Force's comments on radiopharmaceutical reimbursement issues. The SNM pointed out that "there are added costs for acquiring the diagnostic CT data such as for the contrast agent and appropriate nursing and technical personnel. These were not assumed for any previous cost determination, such as for the PEAC, for doing a PET/CT. These costs should be reflected in any new payment scheme proposed. Further, there should be consideration given on how to properly code for a diagnostic CT when performed as single acquisition with a PET/CT." Additionally, the SNM addressed several individual nuclear medicine CPT codes, such as inappropriately moving 78700 to a Level 3 ultrasound APC. The SNM made specific recommendations for appropriate placement and status indicator changes for some nuclear medicine procedures and related drugs and radiopharmaceuticals.

Links to these comments, for your detailed review, are in the Related Items box below.