HAP Radiology Billing and Coding Blog

It seems that diagnostic imaging and radiology are often blamed for increasing the cost of healthcare, especially Medicare costs. Not so, says a recent study that was reported in Radiology Business on August 30, 2021.

A provision of the 21^st Century Cures Act of 2016 took effect earlier this year after several delays and postponements. As of April 5, 2021, providers found guilty of “information blocking” could be subject to significant penalties of up to $1 million per occurrence, although the specifics regarding the process for awarding those penalties have yet to be finalized by the Office of the Inspector General (OIG).   The intent of the law is to promote the free flow of relevant healthcare information between providers and to ensure that patients can access their own information where and when they need it. A better name might have been the “information sharing” or “anti-information blocking” law!

Most radiology practices received an initial distribution of Provider Relief Funds (PRF) from the Department of Health and Human Services (HHS) in April 2020. This was the automatic payment (by direct deposit in most cases) that came without much notice following passage of the CARES Act. Any practice that received more than $10,000 at that time, and chose to retain the funds, is now required to register and report to HHS on the use of those funds.

The term Physician Extender can include a Radiologist Assistant (RA), a Physician Assistant (PA), or a Nurse Practitioner (NP). The rules for use of these Non-Physician Providers (NPP) are different for each one and they vary from state to state according to their licensure laws. In some cases, the practice may bill and be reimbursed separately for the services of a NPP. Understanding the differences is key to getting started with physician extenders.

In our recent article on reimbursement for using artificial intelligence (AI) in radiology, Sandy Coffta mentioned the possibility of new codes proposed by the American College of Radiology (ACR) and other imaging societies. One of those new codes was approved and released on July 1, 2021, for use beginning January 1, 2022. HCPCS^[1] Level II code 0691T (CPT^[2] Category III) will apply to the use of AI for automated analysis of existing CT studies for vertebral fracture(s), including assessment of bone density when performed, data preparation, interpretation, and reporting.

The Centers for Medicare and Medicaid Services (CMS) has released its proposed changes to the Medicare Physician Fee Schedule (MPFS) for 2022. The Proposed Rule is usually modified somewhat before it becomes the final rule for each year, but it gives an idea of the direction Medicare reimbursement is headed. The Medicare Proposed Rule contains payment policy decisions as well as changes to the Quality Payment Program (QPP).

Based on revised recommendations from the US Preventive Services Task Force (USPSTF), the Centers for Medicare and Medicaid Services (CMS) is considering an adjustment to its reimbursement policy for LDCT Lung Cancer Screening. CMS expects to complete its decision-making process before February 2022. In the meantime, many commercial payers have already expanded coverage by adopting the new recommendations.

The long-awaited guidance from the Department of Health and Human Services (HHS) was just released, indicating that the PRF Reporting Portal will be available on July 1, 2021. The latest "Post-Payment Notice of Reporting Requirements" is dated June 11, 2021, which supersedes the January 15, 2021 document, and the HHS website has also been updated with the new rules.

On January 1, 2022, radiology practices and hospitals that perform certain imaging services for Medicare patients will be denied payment for those services unless they submit documentation that the ordering physician has consulted a Clinical Decision Support (CDS) system. This regulation was included a few years ago in Medicare rulemaking, but its effective date has been delayed several times. As of now, there is no reason to believe it will be postponed further, so practices that have not yet taken steps to install and implement a system have a narrow window of opportunity to get ready.

In 2019 we were writing about The Case for Maintaining an Independent Radiology Practice in the Face of Industry Consolidation. Since then, the world has changed dramatically due to the global COVID-19 pandemic. Practice revenue streams were disrupted, while the expenses of operating the practice were ongoing. Radiologists in private practice had to cope with the stress of holding the practice together through the uncertainty. Did the public health emergency alter their thinking about remaining independent, or did it push more of them toward selling the practice to a larger entity?