September 15, 2006

IDTF Letter Campaign Regarding Proposed Changes to the Hospital Outpatient Prospective Payment System (HOPPS) and 2007 Payment Rates

Independent diagnostic testing facilities (IDTFs)/physician office imaging providers are facing two important challenges both of which are inextricably linked with regard to PET scan payments for 2007. The first is the Deficit Reduction Act (DRA) whereby the HOPPS payment rate for imaging services will be the cap for payments to IDTFs under the Medicare Physician Fee Schedule beginning January 1, 2007. Legislative efforts are underway to delay the cuts mandated by the DRA, but the legislation is still pending at this time. The second challenge is the HOPPS rate itself for PET scan payments. CMS is proposing a reduction in payment from the current level of $1,150 for PET and $1,250 for PET/CT to $862 for both PET and PET/CT. (For additional details on the HOPPS 2007 proposed rule as it effects PET please see previous eNews at: http://nps.cardinal.com/nps/PETFoundations/ENews.asp)

CMS is now accepting public comments on the HOPPS 2007 proposed rule until
5 p.m. October 10, 2007


Instructions on how to submit comments are listed at the end of this eNews.

The final rule, which will be published in early November, will set the payment rates under HOPPS for services beginning January 1, 2007. The final rule will also include CMS's responses to public comments received during the formal comment period.

Cardinal Health encourages freestanding PET facilities to submit comments to CMS by participating in a letter campaign that is currently underway. As a service to our customers we have attached the following letter template that is being circulated to IDTF/physician office PET providers to submit comments to CMS on the 2007 HOPPS proposed rule. Each provider should personalize the letter for their own facility and make whatever revisions they deem appropriate.

Download a sample letter: Click Here

How to submit comments to CMS on the proposed rule:
Comments may be submitted in one of four ways (Refer to file code CMS-1506-P).

  • Electronically Submit electronic comments to:
    http://www.cms.hhs.gov/eRulemaking and click on the link "Submit
    electronic comments on CMS regulations with an open comment period".
    Click on Docket ID number CMS-1506-P and follow the instructions
    Note: CMS will accept attachments in WordPerfect, Excel, or Microsoft
    Word (preferred)
  • Regular mail
    Mail written comments (one original and two copies) to the following address only:
    Centers for Medicare & Medicaid Services
    Department of Health and Human Services
    Attention: CMS-1506-P
    P.O Box 8011
    Baltimore, MD 21244-1850
  • Express or overnight mail
    Send written comments (one original and two copies) to the following
    address only:
    Centers for Medicare & Medicaid Services
    Department of Health and Human Services
    Attention: CMS-1506-P
    Mail Stop C4-26-05
    7500 Security Boulevard
    Baltimore, MD 21244-1850

Note: find a print-friendly version of this and other Cardinal Health PET eNews items at http://nps.cardinal.com/nps/PETFoundations/ENews.asp.

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Reimbursement information is provided by Cardinal Health as general coding and payment information. This information is not intended to replace or serve as a substitute for your duty to verify that such information is proper for your particular circumstances. Any codes reported should accurately reflect the procedures performed and the patient's conditions. You may want to consult with local payers to confirm compliance with local policies, or otherwise review and confirm reimbursement policies with your own legal or other professional advisors.

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