HAP Radiology Billing and Coding Blog

The year 2019 marks the third reporting period under the Medicare Incentive-based Payment System (MIPS).  Radiology groups’ performance this year will determine their positive or negative Medicare fee schedule adjustment for payments in 2021, just as this year’s Medicare payment adjustment was determined by performance in 2017.

With the publication of the Medicare Physician Fee Schedule (MPFS) Final Rule for 2019, which includes the Quality Payment Program (QPP) Final Rule, we can now review how radiologists can prepare to maximize their 2021 Medicare reimbursement through QPP participation in 2019.  The QPP includes both the Medicare Incentive-based Payment System (MIPS) and Alternative Payment Model (APM) tracks.  Since most radiology groups are currently participating in MIPS, we will focus on steps to take for successful participation in this program.

The American College of Radiology (ACR) does a very thorough job of reviewing and commenting on proposed federal legislation such as the annual changes to the Medicare Physician Fee Schedule (MPFS).  Their 59-page letter of September 10, 2019 to Seema Verma, Administrator 
of the Centers for Medicare & Medicaid Services (CMS), is available on the ACR website for radiologists to review in detail. 

With the 2017 MIPS reporting year behind us, we now know that practices that achieved the highest possible Final Score of 100 points will receive 2.02% more Medicare reimbursement than the basic fee schedule for 2019.  This increase is compared with the possibility of a 4% payment reduction for practices that did nothing, and a zero-percent adjustment for practices that did the minimum amount of reporting.  In between the minimum level and a perfect score, the fee schedule positive adjustment varies on a sliding scale computed by Medicare.

Recently reported developments in federal health care policy could change the direction radiologists are taking to maintain maximum Medicare reimbursement. 

In an article published in the online Journal of the American College of Radiology¹, authors from Duke University Medical Center Department of Radiology present a study conducted to demonstrate the variability and complexity of radiologists’ dictated notes. The authors chose to analyze the language used to describe normal thyroid glands in chest CT reports as a “surrogate for the broader readability of radiology reports”. In a sample of nearly seven thousand non-contrast chest CT reports, the researchers found 342 unique sentences or phrases describing a normal thyroid gland. Furthermore, linguistic analysis suggested that descriptors for a normal thyroid gland require an advanced college-level education for comprehension. This text is well above the national average health literacy level and results in reports that are difficult for patients to understand.²

In our recent article we explored the ways radiology groups can begin to move toward participation in Alternative Payment Models (APM*) as an option in place of working within MIPS under the Medicare QPP.  But what does APM participation mean for a radiology practice, and what should radiologists look for to begin moving in this direction? 

There’s no doubt that Medicare’s payment for physician services is moving toward a value-based system, and many other healthcare payers are following that lead.  CMS[i] is mandated under MACRA to implement value-based payments.  So far, most radiology practices are struggling to comply with the MIPS branch of the two-pronged MACRA system but the goal of CMS is to eventually move all physicians to the other branch, Alternative Payment Models (APM). 

In a study published in the February 2018 issue of Academic Radiology, Dr. Andrew Rosenkrantz of NYU Langone Medical Center proposes that measuring physician outcomes and resource utilization requires appropriate patient risk adjustment. Using publicly available data from CMS, he and his fellow researchers compared one year of risk-adjustment scores among fifty-four physician specialties to determine the relative complexity of their attributed patient populations. The team analyzed the results for radiologists (31,175 of 549,194 total) based on a range of practice characteristics: teaching affiliations, practice size, geography, and subspecialty.

When Congress finalized the fiscal 2017 federal budget on February 9, 2018, the bill¹ contained some changes that will affect the Medicare Quality Payment Program (QPP) in the coming years. Nothing in the bill changes Medicare payment levels or the MIPS² reporting requirements for 2018. There is, however, a change that affects the 2018 performance year low-volume exclusion.

Here is a summary of the changes: