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Portable X-ray Payment – 2023 Request for Cost Information

In accordance with CMS requirements, National Government Services is conducting a full rate review and a five-year rate update for portable X-ray transportation procedure codes R0070/R0075 for Jurisdiction 6 and Jurisdiction K providers. Accordingly, we are requesting the following cost information from you:

Direct Costs related to the vehicle and personnel transporting the X-ray machine, including:

  1. Depreciation expense associated with the vehicles using a recognized depreciation method. (please state method e.g., three-year depreciation)
  2. The salary, FICA, workers’ compensation, unemployment tax, and fringe benefits associated with the technicians driving the vehicle(s).
  3. The communication equipment used between the vehicle/technician and the home office.
  4. The salary, FICA, workers’ compensation, unemployment tax, and fringe benefits of the despatcher staff.
  5. Repairs and maintenance for the vehicle(s).
  6. Insurance on the vehicle(s).
  7. Operating expenses for the vehicle(s), including gasoline, licenses, and maintenance of the vehicles.
  8. Number of trips taken, their average travel time, average number of miles/trip, and number of patients typically (“on average”) X-rayed per trip.
  9. These figures should be labeled to reflect whether they are monthly or yearly.
  10. A breakdown of the number of trips by Medicare, Medicaid, self-pay, and private insurance components.
  11. If there are other significant direct costs, please include them with an explanation of what they represent.

Indirect Costs or those costs that cannot be directly attributed to portable X-ray transportation:

  • NGS, like all other Medicare contractors, has the discretion to allocate for indirect costs between the transportation service and the technical component of the X-ray tests. Please include any indirect cost that you would like NGS to consider in this process. However, these costs must be specific (e.g., rent, other utilities), and not merely several categories lumped together as “overhead.” They cannot include costs associated with other businesses unless their specific allocation to the portable X-ray transportation business unit and you indicate the percentage of allocation (and method used).

Note: All data supplied should reflect one calendar years’ worth of data (1/1/2022 through 12/31/2022).

In addition, please include a contact name, telephone number, and email address in case we need additional information or clarification. Please send the information electronically to: poej13@anthem.com, we’ve attached an excel spreadsheet for your information. Please return by Friday, 12/15/2023, and use the updated spreadsheet below.

Please let us know if you have any questions.

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As a contractor priced service, MACs must initially determine a payment rate for portable x-ray transportation services that is associated with the cost of providing the service. In order to determine an appropriate cost, the MAC should, at a minimum, cost out the vehicle, vehicle modifications, gasoline and the staff time involved in only the transportation for a portable x-ray service. A review of the pricing of this service should be done every five years.

Direct costs related to the vehicle carrying the x-ray machine are fully allocable to determining the payment rate. This includes the cost of the vehicle using a recognized depreciation method, the salary and fringe benefits associated with the staff who drive the vehicle, the communication equipment used between the vehicle and the home office, the salary and fringe benefits of the staff who determine the vehicles route (this could be proportional of office staff), repairs and maintenance of the vehicle(s), insurance for the vehicle(s), operating expenses for the vehicles and any other reasonable costs associated with this service as determined by the MAC. The MAC will have discretion for allocating indirect costs (those costs that cannot be directly attributed to portable x-ray transportation) between the transportation service and the technical component of the x-ray tests.

Suppliers may send MACs unsolicited cost information. The MACs may use this cost data as a comparison to its contractor priced determination. The data supplied should reflect a year’s worth (either calendar or corporate fiscal) of information. Each provider who submits such data is to be informed that the data is subject to verification and will be used to supplement other information that is used to determine Medicare’s payment rate.

The MACs are required to update the rate on an annual basis using independently determined measures of the cost of providing the service. A number of readily available measures (e.g., ambulance inflation factor, the Medicare economic index) that are used by the Medicare program to adjust payment rates for other types of services may be appropriate to use to update the rate for years that the MAC does not recalibrate the payment. Each MAC has the flexibility to identify the index it will use to update the rate. In addition, the MAC can consider locally identified factors that are measured independently of CMS as an adjunct to the annual adjustment.

Note: No transportation charge is payable unless the portable x-ray equipment used was actually transported to the location where the x-ray was taken. For example, MACs do not allow a transportation charge when the x-ray equipment is stored in a nursing home for use as needed. However, a set-up payment (see §90.4, below) is payable in such situations. Further, for services furnished on or after January 1, 1997, MACs may not make separate payment under HCPCS code R0076 for the transportation of EKG equipment by portable x-ray suppliers or any other entity.

Revised 10/23/2023