HAP Radiology Billing and Coding Blog

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.

The first article in our three-part series covered workplace safety policies, changes to your office space, and workflow processes.  Next, we will discuss the many aspects of human resource management and address patient scheduling in this new environment. 

On June 3, 2020, Congress passed the Paycheck Protection Program Flexibility Act of 2020 (PPPFA) that modifies the Paycheck Protection Program (PPP) that was put in place as part of the Coronavirus Aid, Relief and Security (CARES) Act.  The PPP is a potentially forgivable loan administered by the Small Business Administration (SBA).  This latest legislation changes some of the terms and requirements that will lead to loan forgiveness as we outlined in our recent article. 

There are many variables to consider in addressing the uncertainties that lie ahead. While we know there is a lot of excellent information available, our hope is that we have been able to curate some relevant guidance that will help your practice thrive again in this period of uncertainty.  Areas of focus for your practice should include:

The supply of health care today is directly affected by our care delivery systems. Hospitals have been working hard to meet the demand caused by the pandemic while preserving resources needed for safety. Additionally, in order to do their part in lessening the spread, they have had to quickly adapt to meet precautionary measures and reduce non-urgent and elective care.

The Paycheck Protection Program (PPP) is a loan from the bank that will have to be repaid by the practice with interest unless all or a portion of the loan is forgiven through meeting certain requirements.  Practices with a PPP loan need to be proactive and put themselves in the best possible position for maximum loan forgiveness.  The window of opportunity for forgiveness closes 8 weeks (56 days) from the date the funds are received. Determine this outside date first, and have it burned in the minds of accountants and bookkeepers who provide service to your practice.

The latest legislation designed to assist businesses during the COVID-19 public health emergency is known as the “Paycheck Protection Program and Health Care Enhancement Act”, signed into law on April 24, 2020.  It provides $484 billion to supplement the programs initiated under the CARES^[1] Act, including $310 billion of additional funding for the Paycheck Protection Program (PPP) loans administered by the Small Business Administration (SBA).  There have also been revisions to the Medicare Accelerated and Advance Payment Program and expansion of the HHS “Lost Revenue/Increased Cost” Grants.