HAP Radiology Billing and Coding Blog

The Final Rule related to the No Surprises Act (NSA), issued August 26, 2022, clarifies and modifies the Independent Dispute Resolution (IDR) process but makes no changes to the patient protections and other provider obligations of the NSA, such as notifications and cost estimates for uninsured patients. The IDR process has been the most controversial part of the NSA, especially the stipulation of the Qualifying Payment Amount (QPA) as the primary determinant of reimbursement. The rule finalizes disclosures that insurance payers must share about the QPA and it addresses the information to be considered in the determination of payment under the IDR process.

Practice governance involves hands-on, day-to-day management and oversight, along with a strong basis in group culture and structure. The group’s structure and to some extent its culture is defined in its ownership and operating documents. Our article “Essential Steps to Smooth Practice Governance” that was initially published in the May/June 2022 (Volume 57, Issue 3) edition of the Radiology Business Management Association’s RBMA Bulletin offers a complete review of steps to help your practice operate smoothly through adherence to its foundation documents.

Arterial catheter embolization is an interventional radiology procedure that requires detailed documentation of the steps performed by the physician to maximize coding and reimbursement. The procedure places medications, embolic agents, or a radiopharmaceutical into a blood vessel to prevent abnormal bleeding, close off vessels, eliminate abnormal connections between arteries and veins, or to treat aneurysms or tumors. Common embolization procedures include the treatment of uterine fibroids or the destruction of liver tumors using y-90 radioembolization.

The calculation of reimbursement under the Medicare Physician Fee Schedule (MPFS) is made up of three components, each of which can be adjusted during the annual rulemaking process. The one most discussed is the Conversion Factor (CF), which is the dollar amount applied to the table of Relative Value Units (RVU) to arrive at the reimbursement rate for each procedure; this is known as the National Medicare Fee. However, there is another factor, the Geographic Practice Cost Index (GPCI), that is applied individually to each payment locality across the country. This resulting fee is what is paid to the practice based on the location where the services are performed. The 2023 MPFS Proposed Rule proposes changes to all three components.

Most updates to procedural and diagnosis coding become effective at the beginning of the year, but there are always a few mid-year changes that occur. In recent years, coding has changed to accommodate the COVID-19 public health emergency, and there are a few additions this year as well. Along with those, we’ll also add some reminders about topics that we’ve covered before.

The Centers for Medicare and Medicaid Services (CMS) press release announcing the Medicare Physician Fee Schedule (MPFS) Proposed Rule for 2023 highlights expanded access to behavioral health services, Accountable Care Organizations (ACO), cancer screening, and dental care. Of these areas, cancer screening could be important to radiology practices, but the news was not good – CMS declined to include CT colonography coverage while it expanded coverage for traditional colonoscopy. The MPFS regulates the Medicare fee schedule payment provisions as well as the Quality Payment Program (QPP).

Radiologists at NYU Langone Medical Center have been creating video radiology reports in addition to their traditional text-based reports. The videos are intended for the patient, not the referring physician, and they are uploaded to the patient portal as they are completed. A team headed by Michael P. Recht, MD, studied the results, which became available online April 20 at the American Journal of Roentgenology. An example of a video report is included in NYU Langone’s NewsHub.

The use of teleradiology services was originally framed around the need for a better lifestyle, usually to supplement a radiology group for its call obligation. Teleradiology reading was almost always ‘preliminary,’ with final reports generated by the regular staff, and it was always an expense to the practice that was deemed worthwhile to avoid having to provide night and weekend coverage by the regular staff. Today, the picture has changed to the point where teleradiology services are providing final reports and they have become an indispensable part of the practice that has shifted from a cost center to a profit center.

The shutdown of GE Healthcare’s Shanghai, China plant that began in April has caused a global shortage of the iodinated contrast media iohexol (GE’s Omnipaque ^TM). GE reports that it has returned to a 50% production rate, and they have shifted some production to a plant in Ireland, but they expect an 80% reduction in supplies through June. Alternative contrast agents such as iodixanol (GE’s Vispaque ^TM) and ioversol (Optiray^[1]) are becoming scarce as practices have shifted to using those products instead of iohexol. As of May 31, Omnipaque, Vispaque, and Ultravist (Bayer’s iopromide) have been added to the FDA’s list of drug shortages.

With our first article posted in March 2020, we began a series designed to help you stay abreast of the many regulatory changes and funding opportunities that would help you get through the COVID-19 Public Health Emergency (PHE). The PHE is now scheduled to end on July 15, 2022, unless it is extended for another 90 days, but regardless of exactly when the PHE ends you will need to know what to expect. Some policies will end immediately, and others will end in some number of days later.