Imaging measures: We're from the government and we'd like your help

Which is scarier?

(A)  "We’re from the government and we’re here to help."

or

(B)  "We’re from the government and we’d like your help."

If you answered (B) and you’re in the imaging biz, then: Be afraid.  Be very afraid.

CMS has contracted with L&M Policy Research (a self-described "small, minority/women-owned health policy research firm") and its partners, National Imaging Associates (the "clear leader" in radiology benefits management) and The Lewin Group (OK, we know who they are), "to develop a preliminary set of imaging efficiency measures."

You know where this is heading, right?

Check out the Imaging Measures website, review the draft measures, and file comments (comments due  December 14).  Here are the summary descriptions of the four measures:

Measure One
MRI Lumbar Spine for Low Back Pain

Lumbar MRI is a common study to evaluate patients with suspected disease of the lumbar spine. The most common, appropriate, indications for this study are low back pain accompanied by a measurable neurological deficit in the lower extremity(s) unresponsive to conservative management.

Measure Two
Mammography Follow-up Rates

A recall/call-back following a screening mammography nearly always results in the performance of a diagnostic study. A high percentage (over 10%) of mammogram codes submitted as post-screening diagnostic studies is unusual unless the facility serves as a center specializing in patients with known positive findings on previous exams.

Measure Three
Abdomen CT – Use of Contrast Material

Current literature clearly defines indications for the use of combined studies, that is, examinations performed without contrast followed by contrast enhancement.  The intent of this measure is to assess questionable utilization of contrast agents that carry an element of risk and significantly increase examination cost.

Measure Four
Thorax CT – Use of Contrast Material

Current literature clearly defines indications for the use of combined studies, that is, examinations performed without contrast followed by contrast enhancement.  The intent of this measure is to assess questionable utilization of contrast agents that carry an element of risk and significantly increase examination cost.

CMS says it’s doing what it can to rein in diagnostic imaging costs.  The new website cites MedPAC, which notes that Medicare’s volume and complexity of diagnostic imaging costs rose at nearly twice the rate of physician services costs from 1999 to 2003 (9.9% vs. 5.4%). 

Physicians reading this, and contemplating the looming 10% SGR cut, might have a different take . . . .

Not to head off on a tangent, but physicians have gotten into ancillary services in a big way for three principal reasons — quality control, convenience (doc and patient) and in order to make money, partly in response to declining reimbursement for personally-provided professional services.

Are there some imaging services now being provided that would be deemed inappropriate (and therefore, presumably, eventually unreimbursable under the new measures now being field-tested) but aren’t stopped by current Stark and anti-kickback enforcement?  Sure.  Should CMS develop a professional services fee schedule and update system that doesn’t box physicians into a budget-neutral la-la land?  Of course.

Here’s hoping that CMS is able to tackle both of these issues at the same time.  (Surely there are additional issues that need to be put into the mix as well.)  Otherwise, we’re back to pushing in on one side of the balloon without giving thought to where it will expand on the other side.

— David Harlow