Detailed Review of DI Funding
The Diagnostic Economic Committee (DEC) was charged with developing the College's submission to the Detailed Review of DI Funding (DI Review) announced by the government in the May 2009 budget. The DEC saw the DI Review, together with the broader health care reform agenda, as an opportunity to progress many of the College's strategic priorities, not only in relation to the economic issues and sustainability of DI services, but across all portfolios. The DEC sought to position the College, through its engagement in the DI Review, to influence policy and promote appropriate economic conditions and workforce supply to meet growth in demand for imaging and to support patient centred care. The Review of Funding of Diagnostic Imaging (the Review) was completed on 30 June 2011 and the final report of the review, The Review of Funding for Diagnostic Imaging Final Report, is now available.
Review of Funding for Diagnostic Imaging - Final Report
MBS Quality Framework – Input Based Schedule Fee Setting Mechanism
In parallel with the DI Review, the Department of Health and Ageing has, under the auspices of the MBS Quality Framework, been progressing the development of an input based schedule fee setting methodology which will eventually be applied across the whole MBS, including DI, and which will involve separation of the professional and practice cost components of services. The DEC has been considering the implications of this exercise for the structure of DI rebates and the future funding of DI services as well as for a proposed rewrite of the Diagnostic Imaging Services Table (DIST) recommended by the College as part of its proposed reform of the overall DI delivery framework.
Development of a Body System Structure for the DIST
In the course of exploring issues with the current framework for the funding and delivery of diagnostic imaging services, the DEC formed the view that a body system approach to the structure of the DIST would assist with the proposed restructuring of rebates and had the potential to significantly improve the appropriateness of requesting. A project is being undertaken within the Committee to develop a new anatomical tabular DIST, designed to list DI examinations in a grid with anatomical structures on one axis and imaging modalities on the other axis. Once the new structure has been developed, the grid will be populated with RVUs that attempt to capture both the time based component and the non-time based component of consultant radiologist work. This latter component of the work also has significant potential to assist the College with workforce planning.
Cone Beam CT (CBCT)
In July 2010 the Department of Health and Ageing made an application to the Medical Services Advisory Committee (MSAC) in relation to the use of CBCT for dental and craniofacial imaging, in response to an increase in the utilization of certain items in the DIST. The DEC recommended that the College seek to be involved in the assessment on the grounds that:
- A proliferation of this technology is occurring in Australia including in non-radiology practitioners (eg dental practitioners, ENT specialists);
- Alarms have been raised recently by radiation experts in the United States about the indiscriminate use of CBCT on children by dentists;
- Although being widely used for diagnostic purposes, CBCT is not specifically covered under existing MBS items and there has been no formal evaluation of the technology; and
- The RANZCR has recognized Dental CBCT as a CT procedure that is subject to the same standards of practice as conventional CT and needs to be performed by a suitably trained practitioner.
Following representations from RANZCR the MSAC application has been expanded to include wider diagnostic applications of the technology such as assessing the upper airway in obstructive sleep apnoea and the paranasal sinuses, especially in paediatric patients.
Medicare Benefits Schedule Review of Radiation Oncology Services
The Faculty was advised by the Department of Health and Ageing that the Minister for Health has approved review of a range of Medicare-funded services including all radiation oncology services in 2012-2013.
Without doubt this MBS review will be the single most important issue for radiation oncology profession in Australia in 2012-2013, because of its far-reaching implications for the availability of treatment techniques and of treatment options available to patients going forward.
It is imperative that radiation oncologists work together in this matter to ensure that our ability to deliver a quality service is not compromised. The Faculty will seek expert opinions from all Faculty members in due course.
Billing for fiducial seed markers and MSAC
In November 2009, Department of Health and Ageing (DoHA) notified the AMA (and copied the correspondence to the Faculty) that insertion of gold fiducial seeds into the prostate will be prohibited under the MBS item 37218 from 1 January 2010.
The Department indicated that this decision was foreshadowed by information on item usage from Medicare Australia and instigated by the section of DoHA responsible for urology. To facilitate the speedy progression of this critical matter, the Faculty of Radiation Oncology has commenced work on a Medical Services Advisory Committee (MSAC) submission for a more appropriate MBS number for the use of gold fiducial seeds in image guided radiotherapy (IGRT) of the prostate. The Faculty has also engaged the Urological Society of Australia and New Zealand in the development of this MSAC submission.
Furthermore, the Faculty requested that the Department introduce a moratorium on the reinterpretation of the MBS item 37218 until such time as the specific MBS number for insertion of gold fiducial seeds has been instituted. Based on this advice from the Faculty, the Department agreed to temporarily delay amendments to the MBS item 37218.
Billing for verification items
The Department of Health and Ageing has circulated an announcement regarding changes to the radiation oncology treatment verification MBS items. These changes are consistent with the Faculty’s expectations. Although the situation may not be viewed as ideal by some Fellows; the attitude of the Faculty towards these changes is pragmatic.
Medicare billing for same day consults
It was brought to the Faculty’s attention that there may be an issue billing a patient using the first consultation and planning item numbers, if both were performed on the same day. This often is good practice, and is certainly helpful to the patient if the initial review, consultation and planning can be performed on the same day, especially country patients.
The Faculty sought advice from DoHA and were advised that:
- Both the services must be 'clinically relevant' (that is, generally accepted by the profession as being necessary for the appropriate treatment of the patient - see note T2.1 of the Medicare Benefits Schedule).
- If any radiation oncologists have had any invoices rejected it would be appropriate to send them again to the Department.
- Medicare operators are aware of the previous problem, and so re-submissions should be processed smoothly
- There may have been some confusion because, until early 2009, the MBS Explanatory Notes indicated that benefits were not payable for subsequent consultations rendered on the same day as planning/treatment items, but this restriction was removed to cater for those circumstances where it was clinically relevant to render both services (for example, where a further course of treatment is indicated following a post-course review, and the new treatment can be planned and/or commenced on the same day). DOHA would not, however, expect a consultation item to be routinely claimed if there was no 'clinically relevant' content in that attendance (i.e. where the patient attended primarily for planning or treatment, and there was no clinical need to be seen by a radiation oncologist on that occasion).