HAP Radiology Billing and Coding Blog

Every business in the country has to evaluate its obligation to comply with the Corporate Transparency Act (CTA) by December 31, 2024. The CTA was enacted as part of the Federal Anti-Money Laundering Act of 2020, and the regulations became effective on January 1, 2024. Many practices may already have complied with the law by either submitting the required information or by determining that they are exempt from filing. Failure to comply may invoke civil penalties of $591 per day along with criminal penalties of two years in prison and a $10,000 fine.

In April, 2020, the Federal Medical Assistance Percentage (FMAP) was increased so that states would receive extra funding for their Medicaid programs in support of the COVID-19 public health emergency. In exchange, the states promised to pause Medicaid eligibility checks so that more people would be able to continue to receive Medicaid benefits to get through the pandemic.

Absent any last-minute Congressional action, physicians will suffer a 2.83% fee schedule reduction for 2025. This is slightly more of a cut than had been predicted in the Medicare Physician Fee Schedule (MPFS) Proposed Rule that was issued in July. As we reported in our analysis of the Proposed Rule, this reduction in payments continues a trend that has seen the Medicare fee schedule reduced by nearly 10% over the past 10 years.

We covered the major points of the 2025 Medicare Physician Fee Schedule (MPFS) Proposed Rule when it came out in July, but while we’re waiting for the Final Rule to be published later in the year let’s look at another provision in the MPFS that we’ve been watching – the locality-specific payment adjustment known as the Geographic Practice Cost Index (GPCI).

Ever since it became effective at the beginning of 2022, the No Surprises Act (NSA) has been the subject of legal challenges from the medical provider community. In particular, legal action was filed by the Texas Medical Association, et al (TMA), to challenge the Independent Dispute Resolution (IDR) methodology, which is viewed as more favorable to insurance claims payers and grossly unfair to physicians.

Practices that reported under the Merit-based Incentive Payment System (MIPS) of the Quality Payment Program (QPP) for 2023 can now get their performance score and find out how it will impact their Medicare reimbursement in 2025. The first step is to sign in to the QPP website to get your own practice’s results and review it for any discrepancies. The Centers for Medicare and Medicaid Services (CMS) has released the 2023 MIPS Performance Feedback FAQ’s as a guide to learning more about your practice’s performance.

The Centers for Medicare and Medicaid Services (CMS) has issued its proposal for payments in 2025 under the Physician Fee Schedule (PFS), and it contains an across-the-board 2.8% cut from the current 2024 payment rate. This reduction in payments continues a trend that has seen the Medicare fee schedule reduced nearly 10% over the past 10 years. Last year’s proposed rule (for 2024) contained a 3.36% cut that ended up being a 1.77% cut after Congressional intervention in March, and it is possible that similar action will occur again. The Conversion Factor (CF) in the 2025 Proposed Rule is $32.3562, compared with the $33.2875 currently in use.

The rules and requirements for success in the Medicare Quality Payment Program (QPP) are ever-changing, and it seems like each year brings a new challenge for practices to avoid a payment penalty or, hopefully, to earn a payment bonus. Most recently, CMS announced that the 2023 data submission deadline would be extended until April 15, 2024, due to the cyberattack at Change Healthcare in February, and that practices affected by the cyberattack could apply for an Extreme and Uncontrollable Circumstances (EUC) Exception. The EUC exception allows the applicant to request reweighting of any or all of the performance categories under the Merit-Based Incentive Payment System (MIPS).

The importance of accurate and complete coding cannot be overemphasized for any area of radiology, but the complexity of interventional radiology (IR) coding makes it even more critical for optimal reimbursement. The prerequisite for complete coding is thorough documentation that includes all of the required elements, along with a coding team that is highly trained in IR.

At the April 14 – 17 Radiology Business Management Association (RBMA) PaRADigm Conference in Las Vegas, Rebecca Farrington and Sandy Coffta presented Positioning Your Radiology Group For Success. Their talk was a dive into a captivating exploration of real-world case studies from radiology groups that rode the waves of change. Whether the group soared to success or stumbled along the way, there's a story behind every strategic decision. Rebecca and Sandy unveiled the common pitfalls, the surprise twists, and the must-focus areas for crafting a winning strategy, including the informed choices that helped the groups navigate the intricacies of strategic planning.