Health Policy Affairs

The Society of Interventional Radiology (SIR) has submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed 2027 Medicare Physician Fee Schedule (MPFS) rule. SIR's recommendations focus on protecting patient access to interventional radiology services, preserving fair reimbursement and ensuring federal quality programs reflect the full scope of IR practice.

Key issues for interventional radiology

• Physician payment reductions: SIR urged CMS to discontinue the 2.5% physician work "efficiency adjustment," which continues to reduce physician work RVUs despite increasing patient complexity and demands on physicians.
• Practice expense and site-of-service policies: SIR expressed concerns that proposed payment changes may not accurately reflect the costs incurred by independent physician practices and could affect the long-term sustainability of IR practices.
• Modifier-25 payment cuts: SIR strongly opposed CMS' proposal to reduce payment for evaluation and management (E/M) services reported with modifier-25 when furnished on the same day as a procedure. These services often involve separate clinical decision-making and support efficient, patient-centered care.
• Quality reporting requirements: SIR urged CMS not to eliminate traditional Merit-based Incentive Payment System (MIPS) reporting until interventional radiologists have access to quality measures and reporting pathways that accurately reflect the breadth of IR practice.
  Additional topics addressed

The comment letter also addresses:

•  Medicare physician payment updates and specialty participation in alternative payment models.
• Valuation of CPT® codes affecting interventional radiology services.
• Proposed changes to HCPCS code G2211.
• Teaching physician policies and global surgical package valuation.
• Reimbursement for innovative technologies and high-cost disposable supplies.

SIR thanks the volunteers and staff of its Economics Committee and Quality Division for reviewing the proposed rule and developing recommendations on behalf of the specialty. Through these efforts, SIR continues to advocate for policies that support physician practices, reduce administrative burden, and protect patient access to minimally invasive, image-guided care.