On July 18, 2005, the Centers for Medicare and Medicaid Services (CMS) posted the 2006 proposed rule for the Hospital Out Patient Prospective Payment System (HOPPS) on their HOPPS web site. This proposed rule was published in the August (July?) 25, 2005 Federal Register, on pages 42673 to 43011.

For Medical Imaging professionals, two major CMS proposals could affect your payment rates in 2006:

1. CMS is proposing to apply the multiple imaging reduction to 11 identified families of imaging procedures. This would be based on the type of imaging modality used and contiguous body areas. When two or more procedures are performed in the same family, the first procedure would be paid in full and subsequent procedures would be discounted 50 percent.. Note that CMS is NOT proposing to apply reductions across multiple families. For example, CMS states that no reduction would be applied to an MRI of brain (CPT 70552) in code family 5 when performed in the same session as an MRI of spinal canal and contents (CPT 72142) in code family 6.

2. CMS is proposing to change the status indicator from "K" to "H" for those radiopharmaceuticals for which the hospital median cost is greater than $50. Hospitals would be paid individually, based on their submitted charges, and adjusted by the hospital cost-to-charge ratio (CCR). For example, if your hospital charge is $140 and your HOSPITAL CCR is 0.40, your hospital would be paid $56.00 for that radiopharmaceutical. Be sure you know your HOSPITAL CCR, (which is not your department- specific CCR.)

Medical professional societies are currently preparing detailed comments to CMS regarding these issues. We encourage you to confer with your medical society and to send your comments to CMS. Your suggestions count! Comments will be accepted until 5 p.m., September 16, 2005. You may submit your thoughts online concerning specific issues in this proposed rule. Send them to CMS electronic comments.

CMS plans to publish the final HOPPS rule by November 1, 2005, with an effective date of January 1, 2006.

More details can be found on the CMS HOPPS web site: CY 2006 Hospital Outpatient Prospective Payment System. Note that CMS has already made some corrections to the rule regarding payments for 78814, 78815 & 78816. These are posted on the web site.

The Federal Register, published on July 25, 2005 can be found at: July 25, 2005 Federal Register, pages 42673 to 43011.