DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for ...

CMS-1503-FC 199
ultrasound. Another commenter noted that highly specialized clinics often treat complex
conditions and perform multiple imaging services on noncontiguous body areas primarily
for good patient care. As an example of a situation when complex imaging services are
used to diagnose and treat significant medical conditions, the commenter indicated that a
CT of the chest may be furnished, resulting in a diagnosis of lung cancer. In addition, the
same commenter noted that appropriate treatment of the patient's neurological signs and
symptoms also requires a CT of the head, because primary lung tumors account for 50
percent of all metastatic brain tumors. The commenter explained that these medically
necessary combinations of imaging services are often performed in a single imaging
session. Results of the initial imaging service, contended the commenter, could change
the course of treatment for the patient and it would be prudent not to delay or complicate
a patient's treatment plan. The commenter also pointed out that it is a convenience to the
patient to have same day access for all imaging services.
Another commenter acknowledged that while some efficiencies are gained in
certain situations and settings when multiple imaging services are furnished together, the
expanded MPPR policy would not appropriately pay for the additional studies required
for the majority of patients with significant medical conditions. The commenter
explained that highly organized clinics treating these complex patients often structure
patient encounters so that there are intervening consultations with multiple providers and
additional tests in between imaging services.
Response: While most multiple procedures furnished with a single modality in 1
session would involve procedures currently assigned to 1 of the 11 imaging families, it
would not be uncommon for more than 1 imaging procedure of the same modality to be