Alarming proposals updating payment inputs for myocardial PET that could lead to technical component payment reductions as high as 80 percent for some services, were included in the proposed Medicare Physician Fee Schedule for 2020. These revisions result from updates to the CPT® codes used to report these services and review of the direct practice expense inputs that inform the calculation for the technical component payment. One driver of the cuts is a decision by CMS to assume a 90 percent utilization rate for PET cameras, an assumption that needs to be reconsidered. Pricing information for other equipment may also need to be further refined. The ACC, the American Society of Nuclear Cardiology (ASNC), American College of Nuclear Medicine (ACNM), the Cardiology Advocacy Alliance (CAA) and the Society of Nuclear Medicine and Molecular Imaging (SNMMI) are actively working together on your behalf to address this significant issue.

While the ACC, ACNM, ASNC, CAA and SNMMI support the valuation process used to develop input recommendations administered by the AMA RUC, payment cuts of this magnitude and on such short notice are not sustainable. They could lead to practice disruptions and impact patient access to PET services. ACC, ACNM, ASNC, CAA and SNMMI are aggressively working to correct the inputs and calculations for the payment formula through the public comment process and communication with policymakers. If it becomes clear this cannot be accomplished within the constraints of the rulemaking timeline, we will seek alternative approaches, such as a delay period, to allow further analysis and other efforts to continue.

What You Can Do:

Members who provide PET services can help ACC, ACNM, ASNC, CAA and SNMMI address this proposal in two ways.

1. If you've installed a PET or PET-CT system in the past several years, email jvavricek@acc.org with deidentified paid invoices for the below pieces of equipment. The top four items are the most important as they are being priced for the first time.
• PET Imaging Camera, Cardiac Configuration
• PET Refurbished Imaging Camera, Cardiac Configuration
• PET/CT Imaging Camera, Cardiac Configuration
• PET Generator Infusion Cart
• Professional PACS Workstation
• ECG R-wave trigger (gating) device
• dose calibration source vial set (Cs137, Co57, and Ba137)
• dose calibrator (Atomlab)
• gamma counter, automatic
• radiation L-block tabletop shield
• radiation survey meter

2. The public can comment to CMS directly about the effects these proposals would have on patient care. Explain the impact cuts of this magnitude would have to the Agency here.

As noted above, ACC, ACNM, ASNC, CAA and SNMMI will continue working to correct the inputs for the payment formula through the public comment process and direct communication with policymakers.

Keywords: ACC Advocacy, Current Procedural Terminology, Calibration, Fee Schedules, Medicare, Positron-Emission Tomography, Health Expenditures, Electrocardiography

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