Wylie, John -- NC

As a radiologist, I am extremely concerned with the application of the 50% payment reduction to the professional component of imaging interpretation reimbursement. The following is taken from page 41 of the proposed rule: “This proposal is based on the expected efficiencies in furnishing multiple services in the same session due to duplication of physician work—primarily in the pre- and postservice periods, with smaller efficiencies in the intraservice period.” While I understand that there are efficiencies built into obtaining multiple imaging examinations on the same patient in the same session (with the same modality), these have been reflected in the technical component reimbursement reductions. I take no issue with this concept. However, as a competent, ethical, and moral radiologist, I am obligated to scrutinize every image from every exam that I interpret. At our institution (and nearly every other), a simple non-contrast CT scan of the head has around 70 images, regardless of whether that patient just had a chest CT performed at the same time. Knowledge of the findings on the chest exam has no bearing on my time spent interpreting the brain and vice versa. Therefore, there is literally NO intraservice efficiency, to use the language in the rule document. Additionally, in the PACS era (standard modern radiology workflow) where an exam is opened with a mouse click and the dictation is signed with the same effort, there is no pre- and postservice period. So, all the supposed efficiency that is realized in this period is impossible. It takes exactly the same amount of time to read a CT of the head, c-spine, chest, abdomen, and pelvis on a single trauma patient as it does to read those same exams on five separate patients. Therefore, I urge you to remove this arbitrary provision from the final rule, as it reflects a fundamental misunderstanding (and unfair targeting) of the work my specialty does to take care of our Medicare patients.