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SNMMI Comments on 2019 Proposed Hospital Outpatient Rule

September 25, 2018

SNMMI and the American College of Nuclear Medicine recently responded to the Centers for Medicare and Medicaid Services' 2019 Hospital Outpatient Prospective Payment System (HOPPS) Proposed Rule. The full letter can be found here.

In brief, the organizations thanked CMS for not suggesting changes in nuclear medicine ambulatory patient group categories, as stability in coding and reimbursement is welcome. Further, SNMMI and ACNM objected to CMS' proposal to remove three radiopharmaceuticals from the pass-through list for 2019. The three—C-11 choline, F-18 flutemetamol, and F-18 florbetaben—have reported costs that will make them unaffordable if rolled into APCs that pay no more than $1,400. They also noted that removing two Alzheimer’s drugs from pass-through, while putting another back on pass-through, will make it difficult to obtain coverage for any of the three due to the resulting instability and added challenges for clinical trials. Lastly, SNMMI and ACNM asked CMS to clarify that it will continue to provide additional payments for low-enriched uranium.