On July 19, 2011 CMS published its proposed 2012 Physician Fee Schedule. The 2012 Schedule includes an expansion of CMS’ Multiple Procedure Payment Reduction policy (the “MPPR”) to the professional component of advanced imaging services. The result of the expansion will be a 50% reduction in the professional component payment for 119 imaging services when those services are provided to the same patient and in the same session as other imaging services.

Beginning in 2006, CMS implemented a policy to reduce payment for certain diagnostic imaging services. Citing economies of scale, CMS reduced physician payments by 50% for the technical component of the second and any subsequent CT, MRI, and Ultrasound services when (1) the services were furnished during a single session and (2) the scans were of contiguous body areas. In 2010, the Patient Protection and Affordable Care Act removed the contiguity requirement, and extended the MPPR across modalities. As a result, if a patient received a leg MRI and a neck CT during the same session, the more expensive of the two procedures would be paid at the full rate and the less expensive would see a 50% reduction in the technical component payment.  

The 2012 Schedule proposes to extend the same 50% fee reduction to the professional component of the same services. Therefore, when a patient receives multiple CT, MRI, and Ultrasound scans in the same session, the most costly procedure will be paid in full, but both the technical component and professional component of the additional exams will be paid at 50%. The 2012 Schedule therefore presents significant revenue risk for radiologists. If, for example, a pedestrian were struck by a car and underwent successive CT scans on his head, neck, and back, the reviewing radiologist would be paid in full for his evaluation of the head CT, but would receive only half of the rate for evaluating the other two scans.  

CMS is accepting comments on the proposed 2012 Schedule until August 30, 2011. Comments may be submitted electronically at http://www.regulations.gov under file code CMS-1524-P.