March 3, 2009 - The Medical Imaging & Technology Alliance (MITA) today called on the Centers for Medicare and Medicaid Services (CMS) to reject the Medicare Payment Advisory Commission's (MedPAC) recommendations for significant changes to physician reimbursement rates for advanced medical imaging procedures.
MITA stated that the recommendations in MedPAC’s annual report to Congress were based on flawed and insufficient data, set unrealistic and arbitrary standards for the use of medical imaging and threatens access to life-saving medial services.
“Based on insufficient data and analysis, the MedPAC report makes recommendations that will lead to dramatic Medicare cuts for imaging and have dire consequences for the diagnosis, treatment and care of patients,” said Ilyse Schuman, managing director of MITA.
MedPAC itself acknowledged in its report that it lacked the necessary data required by law to support a recommendation for significant change to the medical equipment “use factor standards,” which guide Medicare reimbursement rates. In its report MedPAC writes, “we recognize that [a change in use factor standards] would require a change in statute because the Balanced Budget Act of 1997 requires CMS to use ‘actual data’ on equipment use” to calculate the use rate.
In addition, MedPAC's survey, which was used to guide its recommendations, excluded key factors that greatly influence imaging utilization rates; most notably the health and age of patients, which are the two most important factors accounting for patient preparation time ? the single biggest determiner of the length of an imaging appointment, and ultimately utilization rates especially in regards to the Medicare population.
MITA called upon CMS and the Department of Health and Human Services (HHS) to work with the medical imaging community to collect accurate data on medical imaging use to help shape policy decisions.
“Setting a standard for medical imagining that is simply not sustainable without the accurate data to support it will be detrimental to providing appropriate medical care. Imaging technology allows accurate data to be collected that can assist policymakers in making better informed decisions about utilization rates and reimbursements,” Schuman said. “We believe that, working in cooperation with HHS and CMS, we can collect data to ensure accurate and fair Medicare reimbursement formulas that will not jeopardize quality care for patients.”
The reductions recommended by MedPAC would further deepen cuts that are already being implemented as a result of the Deficit Reduction Act of 2005 (DRA) and threaten to disrupt access to patient care. According to the Government Accountability Office (GAO), the DRA resulted in $1.64 billion in Medicare cuts in 2007 alone, the first year cuts were implemented, an amount three times larger than what Congress intended. The GAO also found that utilization of advanced imaging services has slowed significantly.
MITA is a staunch advocate for policies that make health care more accessible, enhance the quality of patient care, reduce inefficiencies and remove barriers to appropriate screenings and treatments. Most recently, MITA proposed and supported the appropriateness criteria and mandatory accreditation provisions that were included in last year's Medicare improvement law. Appropriateness criteria focuses on the use of evidence-based guidelines to ensure that medical imaging is utilized appropriately and effectively, without compromising patients' ability to access the right scan at the right time.
MITA called on Congress to incentivize the use of expert physician-developed appropriateness guidelines. Schuman said that “expanding the adoption of appropriateness criteria along with harnessing the power of health IT to reduce duplicative scans will ensure patients get the right scan at the right time.”
Medical imaging has changed the face of health care delivery. From detecting a disease before it becomes deadly to avoiding invasive procedures, physicians and patients rely on the value of medical imaging every day. Medical imaging is not only integral to best practices and professional guidelines, but has reduced hospital stays, returned people to work more quickly, extended lives, and kept families together. These are just a handful of examples of the value and quality of care that the medical imaging industry provides patients and their families.
Schuman stated, “Peer-reviewed data demonstrates that timely access to imaging allows physicians to more accurately identify and treat diseases and care for their patients. When used appropriately medical imaging saves lives and dollars. Appropriateness criteria is the backbone of sound medicine and sound fiscal policy.”
MITA also expressed concern for report’s disregard for the needs of patients in rural areas. The MedPAC report acknowledges that cuts in reimbursement rates for medical imaging may end the ability of doctors in rural areas to provide their patients with access to quality medical services and force patients to travel to centralized hospitals for diagnosis, treatment and care.
Schuman stated, “This report recommends a double standard for patients in rural and urban areas. Patients in rural areas should have the same access to quality care from their own doctor without having travel to a hospital.”
For more information: www.medicalimaging.com
January 28, 2026 
