For CY 2013, CMS proposes to make an additional payment of $10, to cover the marginal costs associated with non-highly enriched uranium (HEU) Tc-99m production. CMS suggests establishing a new HCPCS code, QXXXX (Tc-99m from non-HEU source, full cost recovery add-on, per dose) to describe the Tc-99m radioisotope produced by non-HEU methods and used in a diagnostic procedure.
Hospitals would report this code once per dose along with any diagnostic scan or scans using Tc-99m as long as the Tc-99m doses used can be certified by the hospital as coming from non-HEU. The code would pay hospitals for the additional (marginal) cost of using Tc-99m from a non-HEU source.
What's nice about this proposal is that CMS recognizes that it would be inappropriate to ask hospitals to absorb the marginal cost for radioisotopes produced from non-HEU sources over the costs for radioisotopes produced by HEU sources, Shah says. The CMS suggestion provides an extra payment to ensure that hospitalsreceive appropriate payments in light of the government's agenda to change its HEU policy, she says.
CMS also proposed extending another year the delay on enforcement of physician supervision rules for critical access hospitals (CAH) as well as small and rural hospitals with 100 or fewer beds.
The proposed rule will appear in the July 30 Federal Register. CMS will accept comments on the proposed rule until September 4, and will respond to all comments in a final rule to be issued by November 1. As always, Shah stresses the importance of hospital involvement and urges organizations to provide comments and feedback to CMS.