Public Policy Frequently Asked Questions

What is the Medicare reimbursement for DXA and VFA in 2007?
On a national level, reimbursement for DXA dropped on January 1, 2007 by 41% from $139.46 to $82.33. Additionally, Medicare reimbursement for VFA dropped from $39.41 to $33.10. Reimbursement in your area will be slightly higher or lower due to geographic price adjustments.

The information on the CMS Web site does not reflect the 40% cut to DXA that we were anticipating. Why is that?
Consulting the CMS Web site may be confusing as it may not reflect all cuts to DXA. As of February 9, 2007 the Web site had listed DXA reimbursement for various geographical areas ranging from $72.18 to $143.20. This figure fails to reflect additional cuts due to the Deficit Reduction Omnibus Reconciliation Act of 2005 (DRA) that were implemented on January 1st of this year. Importantly, when CMS corrects this error they have the authority to request these additional monies from your practice.

What are the projected Medicare reimbursement cuts for DXA and VFA by 2010?
Reimbursement for DXA is projected to drop to approximately $36 by January 1, 2010, a decline of 75% compared to 2006 levels. Reimbursement for VFA will drop 50% to approximately $19. As noted above, geographic price adjustments will apply.

Why are the cuts to DXA and VFA so drastic?
Unfortunately, cuts to DXA and VFA came from several sources that combined to produce the profound reductions in Medicare reimbursement. These cuts are:

a. Cuts resulting from changes to the Medicare Physician Fee Schedule— Every five years CMS reviews the Physician Fee Schedule which is the basis for physician reimbursement. All Medicare reimbursement is based upon estimations of costs of physician work, practice expense and malpractice relative to other CPT codes (thus the term RVU or Relative Value Unit). In the 2007 Physician Fee Schedule, CMS cut both the physician work for DXA and the practice expense figures for DXA as follows:

A 33% reduction in the RVU to the physician work component which amounts to an approximate $7 cut in the total DXA reimbursement for 2007. This was recommended by the AMA and its Relative Value Update Committee (RUC).

A 75% reduction in the RVU for practice expense that will be phased in over 4 years which translates into a $23 cut for 2007 and a $91 cut by 2010. This is the result of a new methodology introduced by CMS to calculate practice expense.

b. Cuts resulting from Section 5102 of the Deficit Reduction Omnibus Reconciliation Act of 2005 (DRA). This federal law requires Medicare to cap reimbursement for imaging services performed in the practice (or non-hospital) setting at certain levels. The DRA cut to DXA for 2007 amounts to approximately $24. The intent of the DRA was to control the increased volume of imaging services by implementing cost saving measures.

While controlling the volume of some imaging services is understandable, DXA testing of Medicare beneficiaries currently stands at only ~15%, far below appropriate targets. In fact, numerous Federal initiatives, including the Balanced Budget Act of 1997, United States Preventive Services Task Force and the Surgeon General’s Report on Bone Health and Osteoporosis, have targeted increasing the number of Medicare beneficiaries who are screened for osteoporosis. This goal is clearly at odds with both the changes to the Medicare Physician Fee Schedule for DXA and the objectives of the DRA, which takes aim at reducing the volume of all imaging services, except mammography.

Summary of cuts to DXA for 2007:

Didn’t Congress adopt legislation in the closing days of the last session to restore some of the DXA reimbursement cuts?
There was considerable publicity surrounding the Congressional vote in December 2007 that froze the 5% Sustainable Growth Rate (SGR) cut that was slated to take effect in January 2007. The SGR cuts would have decreased all physician reimbursement by 5%. While most Medicare payments are automatically adjusted each year for inflation, Medicare payments for physician’s services are adjusted every year under a complex formula known as the SGR. This formula is applied to the Physician Fee Schedule unless Congress votes to override its application. Generally, the SGR yields a 4 to 5% cut across the board for all physician services. In each of the past 4 years, Congress has acted at the 11th hour to stop the SGR cuts. The 109th Congress was no exception, voting in the closing hours in December of 2006 to ward off the anticipated 5% cut. Importantly, however, the Congressionally-mandated freeze for 2007 did not affect the cumulative targets that are built in to the SGR. These now amount to an approximate 35% reduction in physician payment by the year 2010. As a result, the SGR for 2008 would be at least 10% to make up for the 5% freeze for 2007.

Additionally, Congress has not addressed the drastic reductions to DXA and VFA that came from other sources—the Deficit Reduction Act and changes to the Medicare Physicians’ Fee Schedule.

Why did the CPT codes change for DXA and VFA? Is there some significance to this change?
The AMA is responsible for assigning CPT codes to various procedures. As part of a general housekeeping measure, the AMA changed the CPT code for axial DXA from 76075 to 77080 and VFA changed from 76077 to 77082. This was not a substantive change and should not alter the way you submit bills for DXA and VFA.

Were there other substantive changes regarding CMS reimbursement for DXA that became effective January 1, 2007?
Yes. Regulations effective January 1, 2007 allow DXA testing for qualified individuals who have been, or plan to be on, a prednisone dose greater than or equal to 5 mg/day as opposed to 7.5 mg/day. The other key change is that central DXA (as distinguished from QCT, ultrasound or peripheral DXA) is now recognized as the only reimbursable test to monitor response to therapy.

What is ISCD doing now to address the reimbursement cuts for DXA and VFA?
ISCD has been working with sister societies such as ACRheum, AACE, TES and ASBMR, patient advocacy groups such as NOF and other stakeholders to urge Congress, CMS and the AMA to do their part to restore DXA and VFA reimbursement to appropriate levels. In December 2006, ISCD helped to coordinate a task force with participation from NOF, ACRheum, AACE, TES, and ASBMR. ISCD is helping to coordinate efforts to fight the DXA /VFA reimbursement cuts on three fronts:

1. CMS –ISCD has been involved in ongoing discussions with CMS since announcement of the proposed cuts in June 2006. We submitted formal comments (to 1521 and 1312) (click to view ISCD comments to CMS 1512 and here for ISCD comments to CMS 1321).  ISCD has met with past CMS Administrator Dr. Mark McClellen and the new administrator, Leslie Norwalk, as well as senior CMS staff. ISCD coordinated a clinical society survey to refute the CMS cost estimates for DXA and VFA. As the result of substantial pressure on CMS from our members, clinical societies and members of Congress, in an unusual move, in December 2006, CMS resubmitted the practice expense figures for DXA and VFA to the AMA’s Practice Expense Review Committee (PERC) and Relative Value Update Committee (RUC) for their review.

2. AMA-During December 2006 and January 2007, ISCD along with The American Association of Clinical Endocrinologists (AACE), American College of Radiology (ACR), American College of Rheumatolgy (ACR), and The Endocrine Society (TES), participated in a re-evaluation of Practice Expense figures for DXA and VFA. On February 1, 2006, RUC Advisors for ACRad, ACRheum and AACE with Dr. Andrew Laster (Public Policy Chair for ISCD, formally invited by ACRheum) presented their recommendations to increase the non-physician work time for DXA from 31 to 46 minutes and VFA from 15 to 20 minutes. Relying heavily on the ISCD clinical society survey data of 453 physicians, this group convinced the AMA’s PERC and RUC to allocate more time for both DXA and VFA. Unfortunately, after the RUC Advisors had departed, the AMA/RUC voted the following day to overturn their vote to increase the values for DXA and VFA and to postpone action on the issue until their next meeting in April of this year.

3. Congress- ISCD is currently working with other stakeholders to encourage Congress to freeze the DRA cuts until a study is done of their impact on access to imaging services. We are hopeful that Congress will act and provide this relief sometime this year. If Congress fails to put a moratorium on the DRA cuts, DXA reimbursement for 2007 will remain at $82.33. ISCD is working with the Access to Medical Imaging Coalition in Washington to repeal or enact a moratorium on the Deficit Reduction Act cuts on imaging procedures which includes cuts to DXA. We expect a bill to be introduced in the next month regarding this issue. ISCD will call on you to at that time to communicate with your Congressional delegation to urge passage of this bill.

ISCD is also helping to coordinate a meeting in Washington, DC on March 1, 2007 to consult with health care policy experts. Our goal will be to draft a bill and plan a media and grassroots strategy to address the DXA/VFA cuts. The meeting will be held at the NOF offices and will include representatives from AACE, ASBMR, NOF, TES, ACRheumatology and others.

What can I do to help restore reimbursement for DXA and VFA to appropriate levels?
ISCD will call on you during the coming weeks and months to help deliver our message to Congress. We expect a bill to be introduced shortly in Congress that will place a moratorium on the Deficit Reduction Act cuts. This would provide some short-term relief while we continue to battle with CMS over the other cuts to DXA and VFA. To facilitate our grassroots effort, we need to locate members in each state who can contact their Congressional delegation, when needed.

If you are willing to help in this effort please click here and we will add your name to our grassroots list. If you have access to any member of Congress (friend, neighbor, acquaintance, etc.) and would be willing to help us deliver our message, please note that information on the grassroots list.

In addition, we are collecting vignettes to include in our materials about how the DXA cuts have affected your ability to treat your patients. If you are discontinuing performing DXA in your office, if you have held off on purchasing equipment, or have story to share about how the cuts will affect your patients, click here and drop us a note. As always, your willingness to help will be essential if we are to win this battle to preserve quality bone mass measurement for our patients.

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Page Last Updated: 12/11/2010

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