HAP Radiology Billing and Coding Blog

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.

Click here to read our 2024 code changes update article.

The recently issued Medicare Physician Fee Schedule (MPFS) Final Rule for 2018 tells us which of the revisions to the Current Procedural Terminology[i] (CPT)^® have been adopted for use in the Medicare system, and how Medicare values those codes.  The diagnostic radiology changes are fairly straightforward, but the Interventional Radiology (IR) coding for Endovascular Repair has been drastically altered with 20 new or revised codes. 

The regulations that will affect Medicare reimbursement for physician practices in 2018 have been released.  They include the Medicare Physician Fee Schedule Final Rule  (MPFS), the hospital Outpatient Prospective Payment System Final Rule (OPPS), and the Quality Payment Program Final Rule (QPP). 

Physicians participating in Medicare’s Merit-based Incentive Payment System (MIPS) have the option of reporting data for 2018 as an individual Eligible Clinician (EC), as part of a group practice that bills Medicare using the same Taxpayer ID Number (TIN), or as part of a Virtual Group.  The latter option is available to a group with 10 or fewer ECs, or an EC in solo practice, who might want to join forces with at least one or more similarly-sized practices for the purpose of reporting their MIPS data for a performance year.  A solo practitioner participating under two TINs may even form a virtual group across both practices.  

When people are referred by their personal physician to a specialist, they usually see the specialist in his or her office for a consultation.  Following the office visit, if the patient and physician deem a procedure to be appropriate, the procedure is scheduled in a facility such as an ambulatory surgicenter or hospital procedure room.  Interventional radiologists, on the other hand, most often see their consultation patients at the time of the procedure in the hospital setting where the procedure will be performed, rather than in their own office.  Changing this approach can yield benefits for the radiology practice, as well as for the patient.