Before the days of managed care, insurance plans were “indemnity coverage” that reimbursed patients for their out-of-pocket costs. Physicians billed the patients and got paid when the patients felt like making payment, usually only after the insurance company had reimbursed them. Often, the insurance money went elsewhere in the patient’s budget and the physician waited for payment. The not-so-good old days! With the advent of managed care contracting where physicians were paid directly by the insurance company, patient balance collections mostly disappeared. Today the pendulum is swinging back in the opposite direction, requiring practices to once again face the necessity to collect significant balances from patients.
If you follow the leading voices in the radiology community, you know that the topic of “value” is a recurring theme of current conversations. It is a core concept behind Imaging 3.0 and has dominated recent seminars, webinars, social media chatter and more for months thanks to MACRA and the many changes it is bringing to provider compensation models. And whatever changes the next wave of governmental healthcare policy washes into the boardrooms of group practices, when the murky waters recede, it is a safe bet that proof-of-value will still remain on the table as a mandate for radiologists going forward.
This is the third in our series of articles designed to help radiology practices prepare for the Merit-Based Incentive Payment System (MIPS). Previous articles covered the Quality Performance Category, which is the largest portion of the MIPS score, and the Advancing Care Information (ACI) Category. Quality will initially account for at least 60% of the total MIPS score and ACI will account for up to 25% of the total score. The Improvement Activities (IA) Category, originally called the Clinical Practice Improvement Activities in proposed regulations, represents 15% of the total score for 2017, the first year of MIPS participation. The fourth element of MIPS, the Cost Category, has been reweighted to zero for 2017.
Medicare publishes its rules and requirements for the coding and billing of medical procedures to obtain reimbursement under its programs, but many commercial insurers are not as transparent about their own requirements. This leaves medical billing professionals in the dark when there are new procedure codes or changes to existing coding in the American Medical Association’s CPT® code set or by federal regulation. Such is the case with mammography coding for 2017. Below we have summarized the key coding considerations for radiology practices billing mammography services this year. (Click here to read our complete article on the 2017 coding changes impacting diagnostic and intervential radiology.)
The annual cycle of revising codes in the Current Procedural Terminology (CPT)® has been completed with the issuance of the Medicare Physician Fee Schedule (MPFS) Final Rule for 2017. For diagnostic radiology, the changes this year are in mammography bundling, ultrasound screening for abdominal aortic aneurysm, and fluoroscopic guidance. Interventional Radiology (IR) will also be subject to bundling and other rearranging of codes for certain procedures. Finally, there are new codes that have been created to describe procedures previously unlisted, which generally will improve reimbursement for those procedures, and codes deleted from use, which will return the affected procedures to the ‘unlisted’ category.
Physicians and other Eligible Clinicians (ECs) who are participating in MIPS under the MACRA rules governing Medicare payments will face requirements that differ depending on whether they are deemed to be “patient-facing” or not. This determination will affect the Advancing Care Information (ACI) and Improvement Activities (IA) components, but not the Quality Performance component of MIPS. In this article, we’ll break-down the key considerations for radiology practices.
By now everyone involved in billing Medicare for physician services should be aware of the new Quality Payment Program (QPP) that will be in effect for payments in 2019 based on data submitted in 2017. The proposed rules for the new system were outlined in our recent article Medicare Quality Reporting Rules are Changing. The final regulations that will govern the new system were recently issued, and radiology practices will benefit from preparing as early as possible to capture the data they will need to report under the new system.
Congress has passed several Acts related to the Medicare payment system over recent years, the provisions of which will begin to take effect in 2017. These changes are embodied in the annual Medicare Physician Fee Schedule Final Rule for 2017 (MPFS) and the Hospital Outpatient Prospective Payment System Final Rule for 2017 (HOPPS). In their initial review of the MPFS, the American College of Radiology (ACR) indicated that it “is pleased with several provisions within the rule.”
Categories: radiology reimbursement
The Merit-Based Incentive Payment System (MIPS) is slowly being analyzed and absorbed by the medical community. This system, passed into law by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), will begin to take effect for physician reimbursement in 2019 but those payment adjustments will be determined by performance in various categories for services rendered in 2017. Regulations governing the application of this law have now been finalized and savvy radiology practices can begin to prepare to comply with the new system.
Earlier this year CMS published its proposed regulations that would implement the MACRA law to revamp the Medicare physician payment system. On October 14th, after consideration of over 4,000 comments about the proposed rules, CMS published the final rule that will govern the initial measurement period that begins January 1, 2017 for payment adjustments in 2019.