Philips Healthcare today submitted comments to CMS on proposed changes in payment rates and policies under Medicare’s Hospital Outpatient Prospective Payment System for calendar year 2009. Among the key recommendations offered by Philips were the following:
- Urged that all capital costs related to diagnostic imaging services be directly allocated to the hospital departments or cost centers involved, rather than across all hospital departments, and that CMS refrain from establishing separate line items or cost-to-charge ratios for CT and MRI services at this time.
- Urged CMS to refrain from “packaging” new imaging services for at least two years.
- Recommended that CMS not implement the proposed imaging efficiency quality measures until the public has had an opportunity to learn about the measures and comment on them knowledgeably.
- Called upon CMS to reconsider the APC rates for fetal echocardiography and myocardial PET
- Urged CMS to take several actions with regard to establishment of composite APCs for imaging services, including delay of composite APCs in trauma and cancer-staging cases, clarification of how composite APCs would impact payment caps for comparable services in non-hospital settings, and clarify composite APCs for services “with” and “without” contrast agents.
To read the comments, please 
click here.