SNMMI has submitted its comments in response to CMS' CY2025 Outpatient Prospective Payment System (OPPS) Proposed Rule. We focus our comments on the unpackaging proposal regarding diagnostic radiopharmaceuticals – a policy of great concern and importance to our members. The SNMMI applauds the agency for its proposal and appreciates CMS’ continued engagement with interested parties on this issue. We provide comments about the specific elements of the proposal below, as well as provide input on specific proposed new technology Ambulatory Payment Classification (APC) assignments.
An overview of our comments can be found below. For our full comments, click the link at the bottom of this page.
Support for Unpackaging Diagnostic Radiopharmaceuticals:
- We strongly support CMS's proposal to unpackage and pay separately for diagnostic radiopharmaceuticals with per day costs exceeding $630. We believe this will reduce financial barriers and improve access to essential diagnostic tests.
- We also recommend a lower threshold of $550, aligning with a 1.75 multiplier, which we believe better identifies high-cost outliers.
Payment Methodology:
- CMS proposes to use the Mean Unit Cost (MUC) from Medicare claims data for payment but also seeks input on using Average Sales Price (ASP) data in unique circumstances.
- We support the MUC approach for 2025 but suggest ASP data is more accurate and should be considered for future years.
- We will recommend CMS finalize the use of the Producer Price Index (PPI) for updating the threshold in 2026 and beyond.
New Technology APC Assignments:
- We support CMS’s proposed new technology APC assignments for myocardial PET/CT studies for CY 2025 and recommends finalizing these as proposed.