Kane, MD, Robert -- MA

Dear Dr. Berwick: The proposal by the Centers for Medicare and Medicaid Services (CMS) to apply a multiple procedure payment reduction (MPPR) to the professional component of advanced diagnostic imaging services administered to the same patient, by the same physician, during the same session is both unwise and unfair. While certain efficiencies may be achieved from the technical component when patients have multiple imaging procedures at the same site and on the same day, the professional component is intended to compensate for the actual work done when interpreting imaging studies. This work is DIRECTLY proportionate to the number of images obtained. For instance, if a multiple trauma patient in the ED has a CT of the head, chest and abdomen, the professional work involved is substantially greater than if only one anatomic site is scanned. Each and every image must be examined and analysed individually, often on multiple separate imaging windows, in order to provide a diagnosis or differential diagnosis for the clinical team. There are no savings or efficiencies whatsoever in this process, and consequently there is no justification in reducing the Professional Component for the second or subsequent scans. Good patient care requires prompt access to appropriate, high quality imaging services, but this proposed MPPR policy will interfere with this goal. Since the professional work is specifically linked to the number of images to be analysed, the PC reimbursement should reflect this fact as a fair and just compensation for the effort involved. Thank you for considering my comments, and please discontinue this mis-applied policy proposal. Robert A. Kane, MD, FACR, FSRU, FAIUM Professor of Radiology, Harvard Medical School Chief-Abdominal and General US Beth Israel Deaconess Medical Center