HAP Radiology Billing and Coding Blog

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?

Benchmarking is a current term used to describe a process that has always been applied but perhaps not in the same way as it is today. That process involves comparing business statistics to historical data or to the same type of data gathered across a wider spectrum. In our May 2019 article How Benchmarking Can Help Radiology Practices Evaluate Their Productivity, we discussed the use of RVUs (Relative Value Units) as a measure of radiologist productivity. This is only one statistic, or metric, that can be used to evaluate a practice’s performance.

The No Surprises Act* will become effective January 1, 2022. This is the first federal regulation that is aimed at protecting patients from receiving unexpected bills from healthcare providers who are outside of their insurer’s network. Review our recent article for an overview of its provisions.

The radiology community is abuzz with talk of artificial intelligence (AI) systems that can assist physicians with image interpretation and perform other tasks. Like any new technology, it will take time before AI gains widespread acceptance due to the cost of implementation. This is analogous to the early-day PACS, where the benefits of efficiency had to be proven in order to justify the expenditure for such a costly system. Today almost all imaging is interpreted on computer systems … when was the last time anyone looked at a piece of film?

At around this time last year we were beginning to learn about the various ways medical practices could make use of federal programs to help keep them afloat through the COVID-19 pandemic. No one knew how long it would last. As time went on, we followed the changes to those programs, the new programs that became available, and the deadlines for action. Let’s review the latest federal legislation and also where each of last year’s relief programs stands today, especially the Medicare Payment Sequester that is a developing story.

The Quality Payment Program (QPP) continues to be modified due to the COVID-19 public health emergency. The Centers for Medicare and Medicaid Services (CMS) recently announced some leeway for clinicians affected by the pandemic in 2020 and 2021.

A radiology practice that includes interventional procedures has to be up to date on the use of documentation and coding techniques for Evaluation and Management (E&M) services. Since these CPT^®[i] codes in the 99xxx range are less commonly utilized in many radiology practices, identifying circumstances where E&M services are billable, and then properly documenting and coding for them, will require a collaborative effort between interventional radiologists (IR) and their coding team.

The issue of patients receiving large, unexpected medical bills from hospitals and physicians has been widely publicized. This situation, known as surprise billing, arises when a hospital or physician provides medical care to a patient but is not participating in a patient’s insurance network. We have reported on the many states that have put legislation in place to try and mitigate the problem for their own residents, but now there will be a nationwide policy thanks to recent federal legislation.