HAP Radiology Billing and Coding Blog

The “Patient Test Result Information Act”, or Pennsylvania Act 112 of 2018, will take full effect on December 23, 2019.  The Act was originally scheduled to begin in December 2018, but the imposition of citations and fines was delayed for one year.  During that time, many hospitals and radiology practices have implemented systems designed to help them comply with this law. 

The 2020 annual update to the ICD-10-CM^[i] system used in medical insurance claim billing became effective on October 1, 2019.  Twenty-one (21) codes were deleted, thirty (30) codes were revised and 273 new codes were added.  The good news for radiologists is that relatively few of these changes will affect your work. 

Any physician who has read about the relatively high award in a recent medical malpractice lawsuit has to be thinking about how they can protect their own practice against a similar outcome from a missed communication with a patient or primary care physician.  In case you missed it, our recent article describes the lessons learned from this case. 

In our recent article we wrote about The Case for Maintaining an Independent Radiology Practice in the Face of Industry Consolidation.  A radiology practice that has served the community with high quality services over many years naturally has developed relationships that can be drawn upon to strengthen its position, and avoid what might otherwise seem to be the imperative to become absorbed by some larger entity.   Some of those existing relationships include the hospital served by the group, its referring physician community and neighboring radiology practices.

The recent award of $10 million in a medical malpractice lawsuit is noteworthy not only for the high amount of the award, but also for what can be learned from the case.  It highlights the consequences of poor patient communication and lack of appropriate follow-up. 

The Centers for Medicare and Medicaid Services (CMS) announced that clinicians who participated in the Merit-based Incentive Payment System (MIPS) in 2018 can access their 2018 performance feedback by logging in to the Quality Payment Program website.   The information should confirm whether you or your practice will receive a positive, negative, or neutral Medicare fee schedule adjustment in 2020 based on the 2018 results.  According to a posting on the CMS website, 98% of eligible clinicians participated in MIPS for 2018, up from 95% in 2017, and 97% will receive a positive payment adjustment by virtue of exceeding the 15-point performance threshold. 

The Centers for Medicare and Medicaid Services (CMS) released their annual proposal for changes to the Medicare payment system for the coming year, and they also released new information about the existing mandate for the use of Clinical Decision Support (CDS) beginning in 2020.  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 2020 and beyond.

We are clearly in an era marked by the consolidation of healthcare services into fewer but larger providers, involving not only hospital systems but physician groups as well.  Radiology practices are not immune to this trend.  The study Radiology Practice Consolidation: Fewer but Bigger Groups Over Time published in April by the Journal of the American College of Radiology shows that practices consisting of 100 or more radiologists grew significantly between 2014 and 2018, while practices of fewer than 100 radiologists declined.  There are many reasons local practices feel the need to become larger, but at the same time there is usually a lot of trepidation among the physicians about joining with another organization.  Before jumping on the merger bandwagon, be sure you’ve considered the ways you can achieve your goals while remaining independent.

Radiologists are most likely not paying much attention to the Merit-based Incentive Payment System (MIPS) Cost category because no specific action is needed to report data, and usually radiology groups have little control over the cost attributed to a patient.  The Centers for Medicare and Medicaid Services (CMS) has released a new MIPS resource on the Cost performance category that provides good information on this aspect of the MIPS scoring.  This affords a good opportunity to review the Cost category and better understand its potential impact on your practice.

Read our 2021 IR billing & coding article 

Proper coding of physician services is essential to efficient billing and the optimization of reimbursement from payers, including commercial and governmental entities.  The CPT^® codes issued by the American Medical Association (AMA) to describe physician procedures are supposed to be recognized as standards, but in practice they are not accepted equally by all payers.  One example is CPT codes in the range 99241-99255 that describe consultation services.  These are most often used by interventional radiologists, as described in our article Coding and Billing Considerations in Interventional Radiology.