HAP Radiology Billing and Coding Blog

The ability to have radiologists work at locations remote from the patient exam site can be a great boon to efficiency and turnaround time. This practice has become more prevalent with the advent of faster network connections, and it has increased significantly since the COVID-19 pandemic when more people began working off-site. Compliant billing for remote reading services is not always as straightforward as normal on-site billing, and radiology practices must be aware of the requirements of each payer, most especially those of Medicare and other government programs.

With passage of the Consolidated Appropriations Act, 2024 (CAA 24), we finally learned the rates physicians will be paid for Medicare services during the remainder of 2024. Effective when it was signed by the President on March 9, 2024 the CAA 24 contained several provisions that benefitted physician reimbursement:

We pay a lot of attention to government regulation in healthcare, especially the Medicare Physician Fee Schedule (MPFS) that influences reimbursement not only from Medicare, but also from other payers since many commercial contracts are tied to the MPFS. Although it is the object of most focus, the Centers for Medicare and Medicaid Services (CMS) is not the only agency that regulates healthcare.

The annual update to the Current Procedural Terminology^[1] (CPT)^® for 2024 has 230 new codes, 70 revised codes, and 49 deleted codes. In addition, there are 395 new diagnosis codes contained in the ICD-10-CM^[2] update, about one-third of them describing new ways to capture accidents and injuries. Although relatively few of these changes will impact radiology practices, it’s essential to know what they are and adjust your practice systems accordingly.

The Centers for Medicare and Medicaid Services (CMS) announced its Medicare Physician Fee Schedule (MPFS) Final Rule for 2024, including provisions for both Medicare reimbursement and the Quality Payment Program (QPP).

During the COVID-19 Public Health Emergency, states were required to maintain enrollment of nearly all Medicaid enrollees as a condition of receiving a temporary 6.2 percentage point Federal Medical Assistance Percentage (FMAP) increase under the Families First Coronavirus Response Act (FFCRA). There was significant growth of national Medicaid enrollment figures due to this continuous Medicaid enrollment requirement, coupled with additional incentives for states to implement Medicaid expansion. The Kaiser Family Foundation estimates that the combination of Medicaid and CHIP (Children’s Health Insurance Program) enrollment has increased by over 23 million people between February 2020 and March 2023. However, when that continuous enrollment condition ended on March 31, 2023, Medicaid enrollment numbers started to decline. States had to resume normal operations, including restarting full Medicaid eligibility renewals and terminations of coverage for individuals who are no longer eligible. The full process could take up to a year, with the earliest removals from coverage having begun in April 2023.

The Strengthening Medicare for Patients and Providers Act (H.R. 2474) would modify the way the Medicare Physician Fee Schedule (MPFS) is calculated and adjusted each year. The basic system of determining Relative Value Units (RVU) would not change, but the annual adjustment of the Conversion Factor (CF) would more closely reflect the actual economic factors that affect physicians’ practices.

For many radiology practices, the idea of a positive payment adjustment for participation in the Medicare Quality Payment Program (QPP) has been lost. Several factors have combined over the past few years to change the goal for radiology practices – it is now ‘penalty avoidance’ rather than a reward for reporting quality metrics. As we outlined in our recent review of the Medicare 2024 Physician Fee Schedule Proposed Rule, the QPP requirements for successful participation are going to become even stricter.

The Centers for Medicare and Medicaid Services (CMS) announced its proposed Medicare Physician Fee Schedule (MPFS) rules for 2024, including provisions for the Quality Payment Program (QPP). While not a done deal until the final rule is issued toward the end of the year, the Proposed Rule gives an indication of where CMS is headed with regard to payment policy. In recent history, even the Final Rule isn’t final because Congress has had to intervene to stave off significant reimbursement reductions. Here are the highlights of the 2024 Proposed Rule.

Complete documentation of any radiology procedure is the key to appropriate reimbursement. This is especially true for venous duplex Doppler ultrasound exams, where including fewer than the required number of elements for a complete procedure will result in reimbursement for a limited study.