On Thursday, August 6, the Centers for Medicare and Medicaid Services (CMS) issued for public inspection the proposed rules on the 2021 OPPS and PFS. Comments are due October 5, 2020. SCMR will continue to review and analyze both rules and provide comments to CMS by the deadline. Below is a brief overview of major provisions of each rule.
Hospital Outpatient Prospective Payment System
Technical Component (TC) Payment
SCMR is pleased to report that CMS proposes increases in TC payment for the majority of the CMR codes for 2021. The OPPS rule governs TC reimbursement for medical services provide in the hospital outpatient setting. TC reimbursement is intended to reflect the non-physician costs of the procedure. SCMR will continue to advocate for more appropriate reimbursement for each code.
75557 – Cardiac MR imaging for struct and morph w/o contrast
75559 – Cardiac MR imaging for struct and morph w/o contrast w/stress imaging
75561 – Cardiac MR imaging for struct and morph w/o contrast, followed by contrast, and further sequences
75563 – Cardiac MR imaging for struct and morph w/o contrast, followed by contrast, and further sequences, w/stress imaging.
We are continuing to analyze the OPPS proposed rule for additional policy changes that will impact the provision of CMR services. Check www.scmr.org for updates.
Medicare Physician Fee Schedule
Conversion factor
The proposed calendar year (CY) 2021 PFS conversion factor is $32.26, a decrease of $3.83 from the CY 2020 PFS conversion factor of $36.09. This is due to policy changes required by law. Along with revisions in the coding structure for certain services (evaluation and management services), this means that some specialties, such as radiology, could see professional component reimbursement cuts up to -11 percent.
Initial calculations for CMR services under the proposed PFS are:
Merit-based Incentive Payment System (MIPS)
CMS proposes the following category weights for the 2021 performance period (CY 2023 payment year). The maximum negative payment adjustment would be -9 percent.
- The Quality performance category to be weighted at 40% (5% decrease from 2020)
- The Cost performance category to be weighted at 20% (5% increase from 2020)
- The Promoting Interoperability performance category to be weighted at 25% (no change from 2020)
- The Improvement Activities performance category to be weighted at 15% (no change from 2020)
For cardiology quality measures, CMS proposes to reassess the appropriateness of individual measures, on a case-by-case basis, to ensure appropriate inclusion in the cardiology specialty set. Of note, CMS proposes to retain these previously finalized measures that pertain to CMR.
Cardiac Stress Imaging Not Meeting Appropriate Use Criteria: Preoperative Evaluation in Low- Risk Surgery Patients: Percentage of stress single-photon emission computed tomography (SPECT) myocardial perfusion imaging (MPI), stress echocardiogram (ECHO), cardiac computed tomography angiography (CCTA), or cardiac magnetic resonance (CMR) performed in lowrisk surgery patients 18 years or older for preoperative evaluation during the 12-month submission period. Measure steward is ACCF.
Cardiac Stress Imaging Not Meeting Appropriate Use Criteria: Routine Testing After Percutaneous Coronary Intervention (PCI): Percentage of all stress single-photon emission computed tomography (SPECT) myocardial perfusion imaging (MPI), stress echocardiogram (ECHO), cardiac computed tomography angiography (CCTA), and cardiovascular magnetic resonance (CMR) performed in patients aged 18 years and older routinely after percutaneous coronary intervention (PCI), with reference to timing of test after PCI and symptom status. Measure steward is ACCF.
Cardiac Stress Imaging Not Meeting Appropriate Use Criteria: Testing in Asymptomatic, Low-Risk Patients: Percentage of all stress single-photon emission computed tomography (SPECT) myocardial perfusion imaging (MPI), stress echocardiogram (ECHO), cardiac computed tomography angiography (CCTA), and cardiovascular magnetic resonance (CMR) performed in asymptomatic, low coronary heart disease (CHD) risk patients 18 years and older for initial detection and risk assessment. Measure steward is ACCF.
For More Information
For a fact sheet on the CY 2021 Physician Fee Schedule proposed rule, please visit:
https://www.cms.gov/newsroom/fact-sheets/proposed-policy-payment-and-quality-provisions-changes-medicare-physician-fee-schedule-calendar-year-4
For a fact sheet on the CY 2021 Quality Payment Program proposed rule, please visit: https://protect2.fireeye.com/url?k=4b7fae8b-172bb7f7-4b7f9fb4-0cc47adc5fa2-dd9a6042df9c69d5&u=https://qpp-cm-prod-content.s3.amazonaws.com/uploads/1100/2021%20QPP%20Proposed%20Rule%20Fact%20Sheet.pdf
To view the CY 2021 Physician Fee Schedule and Quality Payment Program proposed rule, see:
https://s3.amazonaws.com/public-inspection.federalregister.gov/2020-17127.pdf
