HAP Radiology Billing and Coding Blog

Will the requirement to use Clinical Decision Support (CDS) finally become a reality? The current timetable for the penalty phase of the AUC/CDS rule calls for it to begin on the later of January 1, 2023, or the January 1 following the end of the COVID-19 public health emergency (PHE). The PHE has just been extended another 90 days into July 2022, with no end in sight although there are some indications that it could end this year. One source reports that the Administration will give 60 days’ notice before ending the PHE. With this uncertainty, it would be wise for practices to be ready just in case!

This article was updated on
May 3, 2022. 

By now, practices that received grants under the Provider Relief Funds (PRF) program are familiar with the process of reporting on those funds. Reporting on the initial round of funding that came in April – June 2020 (Period 1) was due by November 30, 2021. The second reporting period, for funds received July – December 2020 (Period 2), ended on March 31, 2022. However, the Health Resources & Services Administration (HRSA) recently announced that providers will be able to submit a request to report late due to extenuating circumstances for any reporting period. The request deadline for Period 1 was April 22, 2022. A request for Period 2 must be made online by May 13, 2022.

On July 1, 2022, United Healthcare will begin to implement its Designated Diagnostic Provider (DDP) program for imaging facilities in certain states. According to United’s FAQ document, outpatient MRI/MRA, CT, PET, and nuclear medicine scans must be performed by a Designated Diagnostic Provider in order for members to have the lowest out-of-pocket cost. A member will pay more for services provided by non-DDP imaging facilities.

One of the tools available to assist with the collection of unpaid patient balances is to report the debt to a credit reporting bureau. While typically used as a last resort, it has had the effect of ultimately achieving collection when the patient applies for a loan that requires them to clear up the open balances shown on the credit report. While most physician groups are compassionate and are willing to work with their patients to avoid credit bureau reporting, they are required by insurance laws to pursue collection of patient co-payments and coinsurance. With patient deductibles, copayments and coinsurance increasing in many plans, loss of revenue to the practice through non-collection has become a bigger concern over recent years.

The workload of a radiology practice doesn’t diminish when one of the physicians is away, either on leave or due to termination, and one way to cope with the shortfall of staff is to use a temporary physician service. Knowing how to properly bill for those services is essential to maintaining cash flow in compliance with the regulations.

The decision by a US District Court in a lawsuit brought by the Texas Medical Association has invalidated a portion of the No Surprises Act (NSA). While other similar suits are still pending, this ruling will immediately impact some of the methodology to be used in settling disputes that arise under the NSA.

Interventional radiology is among those specialties hit hard by the clinical labor practice expense cuts in the 2022 Medicare Physician Fee Schedule (MPFS). The proposed Physician Fee Schedule for 2022 contained an estimated 9% cut to interventional radiology (IR), due primarily to the revision of the practice expense component of the RVU calculation. The MPFS final rule brought the IR cut down to an estimated 5% after reconsideration of some of the methodology employed in calculating clinical labor costs. However, this is a blended figure that ignores the much larger effect on the global reimbursement for office procedures than on the professional component for hospital-based procedures.

The Centers for Medicare and Medicaid Services (CMS) has announced a shift in its eligibility criteria for coverage of lung cancer screening using low-dose CT (LDCT), thus joining other payers in adopting recommendations made by the US Preventive Services Task Force (USPSTF).  In addition, CMS made other modifications to its eligibility criteria that will increase the ability of more people to obtain access to screening, effective February 10, 2022 with the posting of its Decision Memo.

The federal No Surprises Act (NSA) has been in effect for a few weeks and many practices are just now beginning to make adjustments to accommodate the law. The level of pro-active involvement might be different for practices working solely in a hospital system from those with a private office or imaging center.

Click here to read our 2024 code changes update article.

There are 249 new codes in Current Procedural Terminology^[i] (CPT)^® that are now in effect for 2022, plus 93 revised codes and 63 deleted codes. However, of all those changes relatively few will impact radiology practices.