CMS Seeking Comments Regarding Expanding Coverage for Secondary Interpretation of Images

by Tucker Arensberg, P.C.
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In the proposed 2015 Medicare Physician Fee Schedule, CMS is seeking comments regarding expanding coverage for secondary interpretation of diagnostic imaging.

I’m enclosing pages 40370 and 40371 of the proposed Medicare Physician Fee Schedule. The enclosed material sites the Medicare Claims Processing Manual provisions which make is clear that a professional component interpretation service should only be billing for the forward interpretation and report, and then Medicare pays for only one interpretation of an EKG or x-ray service to an emergency room patient.

CMS is acknowledging that technological advances such as the integration of picture and archiving communication systems across health systems and the growth of image sharing networks and health exchange platforms, make it possible for providers to share images, and that covering payment for second interpretations would contribute to improve care and potentially reduce costs by eliminating the need to perform the full professional and technical component of additional images. Specifically, CMS is seeking comment on the following questions:

  • For which radiology services are physicians currently conducting secondary interpretations, and what, if any, institutional policies are in place to determine when existing images are utilized? To what extent are physicians seeking payment for these secondary interpretations from Medicare or other payers?

  • Should routine payment for secondary interpretations be restricted to certain high-cost advanced diagnostic imaging services, such as those defined as such under section 1834(e)(1)(B) of the Act, for example, diagnostic magnetic resonance imaging, computed tomography, and nuclear medicine (including positron emission tomography)?

  • How should the value of routine secondary interpretations be determined? Is it appropriate to apply a modifier to current codes or are new HCPCS codes for secondary interpretations necessary?

  • We believe most secondary interpretations would be likely to take place in the hospital setting. Are there other setting in which claims for secondary interpretations would be likely to reduce duplicative imagine services?

  • Is there a limited time period within which an existing image should be considered adequate to support a secondary interpretation?

  • Would allowing for more routine payment for secondary interpretations be likely to generate cost savings to Medicare by avoiding potentially duplicative imaging studies?

  • What operational steps could Medicare take to ensure that any routine payment for secondary interpretations is limited to cases where a new imaging study has been averted while minimizing undue burden on providers or Part B contractors? For instance, steps might include restricting physicians’ ability to refer multiple interpretations to another physician that is part of their network or group practice, requiring that physicians attach a physician’s order for an averted imaging study to a claim for a secondary interpretation, or requiring physicians to identify the technical component of the existing image supporting the claim.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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