On August 16, 2004, the Centers for Medicare and Medicaid Services (CMS), the federal agency that administers the Medicare Program, issued its annual proposed regulation updating the Medicare hospital outpatient prospective payment system. The proposed rule outlines three payment options for the average technical reimbursement rate for FDG PET procedures, effective January 1, 2005.

This proposed rate change applies to PET imaging procedures performed in hospital outpatient departments only and does not affect freestanding imaging centers that bill for PET procedures under the Medicare physician fee schedule. In addition, payment for FDG is covered by a separate rate.

The CMS payment options include the following:

Option 1: Continue to assign FDG PET procedures to New Technology Ambulatory Payment Classification (APC) 1516.
This would result in a payment rate of approximately $1,450 in 2005.

Option 2: Assign FDG PET procedures to a clinically appropriate APC priced according to the median costs of the scans, based on 2003 claims data.
This would result in a payment rate of approximately $899 in 2005.

Option 3: Set the payment for FDG PET procedures based on a 50-50 blend of New Technology APC payment rate (Option 1) and the median cost (Option 2).
This would result in a payment rate of approximately $1,150 in 2005.

We believe that it is vital for CMS to continue to reimburse hospital providers for FDG PET procedure at current rates in 2005. This will ensure that Medicare patients continue to have access to this important medical advance at a time when CMS plans to expand coverage to FDG PET to include additional clinical indications such as Alzheimer's Disease and dementia.

As a provider of PET imaging services, we request your help in voicing support for maintaining the current FDG PET payment of $1,450 in 2005 (Option 1).

Please take advantage of the comment period for this proposed rule to make your views known to CMS. We have developed a sample comment letter that you can use to submit your comments to CMS. See the link below for the sample letter.

Comments may be submitted to CMS in one of two ways:

1. By mail, and you may use the sample letter below. Send one original and two copies of your comment letter to:

Centers for Medicare and Medicaid Services
Department of Health and Human Services
Attention: CMS-1427-P
P.O. Box 8010
Baltimore, MD 21244-8018

2. By Express Mail, and you may use the sample letter below. Send one original and two copies of your comment letter to:

Centers for Medicare and Medicaid Services
Department of Health and Human Services
Attention: CMS-1427-P, Room 445-G
Hubert H. Humphrey Building
200 Independence Avenue SW
Washington, D.C. 20201

This issue is of great urgency to GE Healthcare, the PET community and - most importantly - the patients we serve. Thank you for your support.

Sincerely,
Jeffrey Kao
GM - Functional Imaging
Nuclear Medicine and PET
GE Healthcare Technologies

• Sample letter