HAP Radiology Billing and Coding Blog

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:

Our recent article How Radiology Practices Can Drive True Quality of Care describes how the use of clinical data can be integrated with a business process to provide benefits for both patient care and practice value.  Expanding this concept to the next level triggers the imagination – what other types of cases in the practice need follow-up within specific time periods?  Thus came the idea for the second iteration of HAP’s clinical analytics solution deployment that involved patients with implanted inferior vena cava (IVC) filters.

A recent study^[1] published by the Journal of the American College of Radiology concludes that clinicians prefer radiology reports in a more structured format over those in a “more traditional, prose style”.  This finding supports the position we at Healthcare Administrative Partners have long advocated.  Our May 2016 article points out the many benefits of structured reporting, which include easier transition to clinical decision support systems, compliance with quality reporting standards, and fewer denials from payers for questions of medical necessity or coding at the appropriate level of service.

Radiologists often identify incidental findings.  When clinically significant, communicating these findings for further evaluation and treatment can be a lifesaving action.  Despite best efforts, documentation in radiology reports does not adhere to a fixed standard, making subsequent analysis of incidental findings quite difficult.  And, while such a finding might be insignificant in the present exam, over time a patient’s status may change and incidental findings may be a key indicator of appropriate follow-up care. 

Converting the US healthcare economy to a value-based model that rewards both quality and cost savings is an objective that still holds bipartisan support, despite the well-known burdens of compliance that many providers have experienced.  While some significant voices are currently advocating repeal and replacement of MIPS, others are for "charging forward". 

The Centers for Medicare and Medicaid Services (CMS) threw a surprise into the Quality Payment Program (QPP) Final Rule for 2018 when it included the Cost Category as 10% of the MIPS Final Score for 2018 reporting.  The QPP Proposed Rule issued a few months earlier stated that Cost would be zero-weighted for 2018 as it had been in 2017.  So what does this mean for radiology?

During 2016 we worked hard to provide our readers with information and advice that would allow them to maximize their performance under the Physician Quality Reporting System (PQRS) and therefore to maximize their reimbursement in 2018 under the associated Medicare Value-based Payment Modifier (VM).  The results have just been announced by the Centers for Medicare and Medicaid Services (CMS), and are available in a CMS Fact Sheet.

With the release of the final Medicare Physician Fee Schedule for 2018 (MPFS), we learned that application of the Appropriate Use Criteria/Clinical Decision Support (AUC/CDS) requirement that was originally scheduled to begin in 2018 has been deferred until January 1, 2020.  Nonetheless, since AUC/CDS is embodied in the Protecting Access to Medicare Act (PAMA 2014), CMS has no choice but to implement it at some point.  While radiologists can breathe a sigh of relief for the moment, setting up and testing their system should be an ongoing project over the coming years.

The first performance measurement year of the Medicare Incentive-based Payment System (MIPS) was 2017, the results of which will be used to determine Medicare payment adjustments in 2019.  This was considered a “transition year” that allowed practices to “pick your pace,” ranging from a streamlined path that would simply avoid penalties in 2019 to full participation that could generate positive payment adjustments in 2019.  The bar has been raised for 2018 performance measurement, and it will continue to be raised again in 2019 as the program reaches full implementation as required by law.  This article summarizes the changes for 2018 that will affect the performance of radiology practices as they work to maximize their reimbursement in 2020.