HAP Radiology Billing and Coding Blog

The Medicare reimbursement rates for 2025 remain unchanged as a result of the Continuing Resolution (CR) passed by Congress and signed on March 15. Thus, the downward spiral of Medicare reimbursement continues with physicians receiving nominally 2.83% less this year than in 2024. Radiology practices will see somewhat different results depending on their practice pattern, as we reported in our recent article analyzing the real impact of the Medicare Physician Fee Schedule (MPFS). We calculate that the Professional Component reimbursement would decrease 2.16%, while global reimbursement at an imaging center would decrease by 3.55%, both on a weighted-average basis.

The 2025 conversion factor (CF) that sets the overall rate for the Medicare Physician Fee Schedule (MPFS) was adjusted downward by 2.83% from the 2024 rate, to $32.3465 per Relative Value Unit (RVU) vs. $33.2875 per RVU. Several bills are pending in Congress that would mitigate the scheduled reduction, at least on a temporary basis, or perhaps to make more permanent corrections to the Medicare pricing formula. However, as of this writing none are in active discussion.

Radiology practices often participate in the Quality Payment Program (QPP) through the Merit-based Incentive Payment System (MIPS). Many aspects of the MIPS rules remain unchanged for 2025, including:

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.

The 2025 update to the Current Procedural Terminology^[i] (CPT)^® has 270 new codes, 38 revised codes, and 112 deleted codes. In addition, the ICD-10-CM^[ii] update has over 300 revisions, additions and deletions. Although relatively few of these changes will impact radiology practices, it’s essential to know what they are and adjust your practice systems accordingly.

Mammography remains one of the most critical areas of radiology practice, and one that is facing changes in reporting requirements and reimbursement policy. Even with additional mammography reporting requirements placed on radiology practices, the reimbursement value of mammography services has not changed to reflect the extra work. However, changes to screening policy could provide increased mammography volume.

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.

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.