HAP Radiology Billing and Coding Blog

The COVID-19 pandemic spawned many programs designed to assist medical practices to stay afloat financially through the duration of the public health emergency. The terms and conditions of many of the various relief programs have changed since they were first introduced, and it often is a challenge to keep up with the latest rules. The Department of Health and Human Services (HHS) has now announced another round of Provider Relief Funding (PRF) and the terms of the Medicare Accelerated and Advanced Payment Program have recently been modified.

Quality Payment Program (QPP) participants can now obtain information about whether their practice will receive a positive, negative, or neutral Medicare fee schedule adjustment in 2021 based on the 2019 data they submitted. The Centers for Medicare and Medicaid Services (CMS) announced that clinicians who participated in the Merit-based Incentive Payment System (MIPS) in 2019 can access their performance feedback by logging in to the Quality Payment Program website. 

One of the fastest and easiest sources of emergency funding available to practices at the outset of the COVID-19 pandemic was the Medicare Accelerated and Advanced Payment Program.  As we recently reported, the initial timetable called for repayment of those advances to begin 120 days after the advance was made. Repayment was to be accomplished through reduction of Medicare reimbursements otherwise payable to the practice currently, until the full amount of the advance was repaid.

The average cut of 11% in radiology reimbursement that is proposed by the Medicare Physician Fee Schedule for 2021 (MPFS) is the continuation of a trend that spans more than a decade.

The Centers for Medicare and Medicaid Services (CMS) has released their annual proposal for changes to the Medicare payment system for the coming year. The Medicare Physician Fee Schedule (MPFS) Proposed Rule contains not only proposed adjustments to Medicare reimbursement but also proposed changes to the Quality Payment Program (QPP) for 2021 and beyond.

Much has been written about the Paycheck Protection Program (PPP) loans and the complex rules for loan forgiveness, but there were other funding sources available early in the public health emergency that need to be revisited now.   Our article in April outlined the HHS Grant Funds and another article discussed the Medicare Accelerated & Advance Payments Program.

Radiologists who perform venous ablation in a hospital outpatient department are now required to obtain prior authorization before performing such services on Medicare patients.  This new requirement became effective for services performed on or after July 1, 2020, and physicians were notified by letters from the Centers for Medicare and Medicaid Services (CMS) late in June.  The prior authorization requirement was included in the 2020 Hospital Outpatient Prospective Payment System (HOPPS) Final Rule, and encompasses the following procedures that might be performed by interventional radiologists:

Since the end of March we all have been focused on the impact of the public health emergency created by the COVID-19 pandemic, but slowly our attention is returning to the other ongoing issues of operating a practice.  Let’s review some important topics that still exist on our radar screens.

We now have more concrete details about the revisions to the Paycheck Protection Program (PPP) that were outlined in our recent article following passage of the Paycheck Protection Program Flexibility Act (PPPFA).  The PPP Loan Forgiveness Application (SBA Form 3508) has been revised and a new simplified application (SBA Form 3508EZ) is also available, along with instructions, from the SBA website. 

The first article in our three-part series covered workplace safety policies, changes to your office space, and workflow processes, while the second article discussed human resources and patient scheduling considerations.  In this final article, we look at ways to strengthen the return of patient volume to your practice through community collaboration and marketing.