Noting significant growth in imaging services paid by Medicare under the physician fee schedule, the Medicare Payment Advisory Commission (MedPAC) advanced several recommendations aimed at increasing the appropriate use of imaging services in its June report to Congress. These include prior authorization requirements for physicians who order significantly more advanced imaging tests (e.g., MRIs) than their peers, specified as the top ten percent of providers. Other recommendations relate to payment reductions for imaging services. For example, one proposal addresses cases where two or more imaging services are performed in the same encounter. Certain imaging services comprised in a multiple procedure currently are subject to payment reduction; however, this reduction is limited to the technical component of the test. MedPAC recommends including the professional interpretation and also proposes payment reductions when the same physician orders and performs a diagnostic test.

The MedPAC recommendations have prompted responses from affected practitioners and organizations. With respect to the prior authorization proposal, a requirement that has not been used in the Medicare program, commenters stress the impediment to patient access and the administrative burden on providers. Pointing to the significant payment cuts on advanced imaging services imposed by prior legislation, commenters cautioned that further cuts could result in a shifting of imaging services to the more costly hospital setting. In lieu of payment cuts and prior authorization requirements, the commenters urged that MedPAC consider alternatives such as the use of evidence-based, physician-developed appropriateness criteria for curbing overutilization of advanced imaging services.