Beginning in 2019 the level of reimbursement from Medicare to many physicians will be determined in part by their performance in the Merit-based Incentive Payment System (MIPS). Medicare will award a higher level of payment to those eligible clinicians and groups who report that they have successfully met certain criteria for Quality, Advancing Care Information, and clinical practice Improvement Activities. MIPS is the successor program to the Physician Quality Reporting System (PQRS) and Meaningful Use of Electronic Health Records (MU-EHR) incentive programs, and CMS (the Centers for Medicare and Medicaid Services) has indicated that it will continue its practice of auditing the data submitted by practices just as they did under the earlier programs. As this article in Healthcare IT News illustrates, the result of failing an audit will be non-payment of expected incentives (in the case of a pre-payment audit) or returning of funds already paid and possibly even federal sanctions depending on the severity of the infraction.
In the August 4, 2017 edition of its Advocacy in Action eNews the American College of Radiology (ACR) reported on the Centers for Medicare and Medicaid Services (CMS) announcement regarding the manual application process for a significant hardship exception under the Advancing Care Information (ACI) category of MIPS.
The annual regulatory cycle of review, comment, planning and preparation has begun with the release of the Medicare Physician Fee Schedule (MPFS) Proposed Rule for 2018. In its preliminary review of those sections of the MPFS that will be of specific interest to radiology practices, The American College of Radiology (ACR) includes a statement that “the ACR is pleased with several provisions within the rule.” They highlight the planned implementation of the Appropriate Use Criteria and Clinical Decision Support rules beginning January 1, 2019 and the proposal to leave the technical component of mammography services unchanged rather than lowering it by 50% as previously discussed.
New information has been provided by The Centers for Medicare and Medicaid Services (CMS) that will supplement our article An Update for Radiologists on Appropriate Use Criteria and Clinical Decision Support. We can now update you from the recent release of the “Proposed Medicare Physician Fee Schedule (MPFS) for 2018” and the “Proposed Rule for Quality Payment Program Year 2.”
Patients in rehabilitation facilities sometimes need imaging services that cannot be provided within the facility itself. Imaging centers willingly accept these patients but they can inadvertently fall into a collections quagmire if they aren’t aware of the Medicare rules related to skilled nursing facilities.
Radiologists considering the use of an outside service for final reads will have questions that include not only quality and cost but also the impact on the group’s relationship with its hospital and referring physician community. The answer will not be the same for every radiology practice. Here we present some of the pros and cons for consideration in the decision-making process.