SVU Member Survey: Summary of Calendar Year 2026 Proposed Medicare Payment Rules
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1.
What’s top of mind for you about the CY2026 proposals?
2.
Your setting (select all that apply)
Hospital Outpatient Department – on-campus
Hospital Outpatient Department – off-campus (excepted/“grandfathered”)
Hospital Outpatient Department – off-campus (non-excepted)
Physician office
Independent Diagnostic Testing Facility (IDTF)
Other (free-text)
3.
Medicare share of your vascular ultrasound volume
<25%
25–49%
50–75%
>75%
Unsure
4.
Which services are a regular part of your Medicare work? (check all)
Carotid duplex (e.g., 93880/93882)
Transcranial Doppler (TCD) (e.g., 93886–93898)
Physiologic arterial testing (e.g., 93922-93924)
Dialysis access evaluation (e.g., 93990)
Venous duplex (e.g. 93970 bilateral/93971 unilateral/limited)
Complete bilateral physiologic studies, upper or lower extremity arteries, 3 or more levels: 93923 or lower extremity arteries at rest and following treadmill: 93924
Duplex scan of aorta, IVC, Iliacs, bypass grafts; complete study (93978)
Monitoring/ initial access mapping in ESRD patients: other codes such as 93985/6 may apply
5.
For any that selected above, estimate the number of Medicare exams/months?
0-10
11-25
26-50
51-100
>100
6.
Turning to APC’s: CMS assigns CPT codes for outpatient services to an Ambulatory Payment Classification (APC) group. APCs are hierarchical, with different levels reflecting varying resource intensity and cost.
APC 5522: Level 2 Imaging without Contrast. This is for less complex, lower-cost imaging services(93931, 93971, 93979, 93926,)
APC 5523: Level 3 Imaging without Contrast. This is for more complex, higher-cost imaging services.(Example: 93880, 93925, 93930, 93970, 93975, 93078, 93925, 93930)
7.
If you bill in HOPD, what is your current mix between APC 5522 vs 5523 for vascular ultrasound?
Mostly APC 5522 (>70%)
A mix (about 40–60% either way)
Mostly APC 5523 (>70%)
Not sure / N/A
8.
For non-facility sites (physician office/IDTF): are you seeing OPPS cap–limited payments on any vascular ultrasound codes?
Yes
No
9.
Comparator insight: carotid duplex vs echocardiography
Do you perform both exams in your organization?
Yes – carotid duplex and transthoracic echo (TTE)
Yes – carotid duplex and transesophageal echo (TEE)
Both TTE and TEE
No/Unsure
10.
If Yes to the above question: Based on typical cases, overall resource intensity (time, staff, equipment/room) is:
Similar for carotid duplex and echo
Echo is higher than carotid duplex ( Unsure: TEE usually higher- should we differentiate?)
Carotid duplex is higher than echo
11.
CMS has hinted at possible volume controls for Imaging Without Contrast APCs (5521–5524): if adopted in the future, The APC group would include a different level of imaging complexity, affecting reimbursement:
APC 5521: Level 1 Imaging without Contrast
APC 5522: Level 2 Imaging without Contrast
APC 5523: Level 3 Imaging without Contrast
APC 5524: Level 4 Imaging without Contrast
12.
What would the expected impact on your HOPD program be:
Significant Negative
Moderate Negative
Minimal/none
Unsure
N/A
13.
Name (Optional)
14.
Organization (Optional)
15.
Email (optional)