HAP Radiology Billing and Coding Blog

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.

From Wednesday, February 24 to Wednesday, March 10, practices with fewer than 20 employees will have a preferential opportunity to obtain a loan under the Paycheck Protection Program (PPP). According to the Small Business Administration (SBA), “This will give lenders and community partners more time to work with the smallest businesses to submit their applications, while also ensuring that larger PPP-eligible businesses will still have plenty of time to apply for and receive support before the program expires on March 31, 2021.”

Most of the annual changes to diagnosis coding under ICD-10^[i] system take effect on October 1, but other changes occur during the year. There are quite a few codes that became effective on January 1, 2021, all related to COVID-19 conditions.

When the Medicare Physician Fee Schedule (MPFS) Final Rule was published in December, it looked like radiology was facing a significant cut in Medicare reimbursement for 2021. Our article reported that professional component fees would drop 10-11% while global reimbursement would see a lesser impact. The Consolidated Appropriations Act, 2021 (CAA) rolled back those cuts at least for 2021, although the Medicare fee schedule for radiology will likely continue to be adjusted downward in the future as implementation of the revalued Evaluation and Management (E&M) services is fully phased in.

The “Consolidated Appropriations Act, 2021” (CAA) is a sweeping piece of legislation that provides relief to individuals and businesses impacted by the COVID-19 public health emergency. Some of the relief provisions apply to all businesses, including medical practices, but it also contains several measures that specifically apply to medical practices.

Click here to read our 2025 code changes update article.

The big news in Current Procedural Terminology^[i] (CPT)^® revisions for 2021 is the overhaul of the Evaluation and Management (E&M) section, reducing documentation requirements, and introducing new rules for determining the level of coding. These changes will affect interventional radiologists and radiation oncologists more than they will the day-to-day work of diagnostic radiologists. First, we will review the other non-E&M code changes affecting diagnostic and interventional radiology for 2021.

The Centers for Medicare and Medicaid Services (CMS) has released the final set of rules that will govern the Medicare payment system for the coming year, thereby affirming the drastic cut in radiology reimbursement for 2021 that was proposed earlier this year.  There were few surprises in the Medicare Physician Fee Schedule (MPFS) Final Rule that were not contained in the proposed rule, other than a slight improvement in the fee schedule conversion factor and a change to the QPP Performance Threshold.