HAP Radiology Billing and Coding Blog

Participation in Medicare’s PQRS program is important to radiologists in order for them to maintain full reimbursement under the Medicare fee schedule, and to perhaps earn a higher level of payment in future years. Radiologists providing services in Independent Diagnostic Testing Facilities (IDTFs) will not be able to participate in PQRS, according to a ruling described in the June 16, 2015 issue of the RBMA Washington Insider. This most recent guideline issued by the Centers for Medicare and Medicaid Services (CMS) clarifies past guidance by stating, “After further review, CMS is announcing that EPs [eligible professionals] who provide services under an IDTF or an independent lab (IL) (and on behalf of services provided by that IDTF or IL) are not able to participate in PQRS. Therefore EPs who provide services [billed] under an IDTF or IL will not receive the 2015-2018 PQRS payment adjustments for services associated with the IDTF or IL”. This reverses CMS guidance issued as recently as March, 2015.

A report issued by the Office of the Inspector General (OIG) on May 6, 2015 found that Medicare overpaid physicians approximately $33.4 million for services performed in facility locations that were incorrectly coded as performed in non-facility locations, such as ambulatory surgery centers and hospital outpatient departments. The physicians identified in the audit will have to reimburse Medicare for the overpayments.