HAP Radiology Billing and Coding Blog

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 2024 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.

It’s been a while since we looked at the Paycheck Protection Program (PPP) and its loan forgiveness feature. Since the beginning of the program in April it has undergone some revision, many questions have been answered, and yet the answers to some questions remain unclear. Currently there is much discussion of when to file the application for loan forgiveness, with renewed concern about the taxation aspects of the PPP.

There are 490 new ICD-10-CM^[i] codes that became effective on October 1, 2020, all of which are replacing existing codes. An additional 47 codes have been revised and 58 were deleted. Two new codes, U07.1 for COVID-19 and U07.0 for vaping-related disorders, took effect on April 1, 2020. They are contained in a new section of the guidelines, Chapter 22 “Codes for Special Purposes (U00 – U85)”.

The treatment of liver tumors using yttrium-90 (y-90) radioembolization brings unusual challenges for interventional radiologists (IR). Documentation of treatment planning, radiation dosimetry calculations and placement of radioactive sources are not usually a familiar part of their lexicon. It is these unfamiliar disciplines, along with more comprehensive Evaluation and Management (E/M) visits, that set this procedure apart from the more routine IR cases.

Radiologists practicing in an imaging center or other non-hospital facility have a new tool available that will potentially allow them to recover some of the added costs related to safety precautions taken during the COVID-19 public health emergency. CPT code 99072 was added by the American Medical Association (AMA) Current Procedural Terminology (CPT^®) Editorial Panel on September 8, 2020, with immediate effect. While payment for this code is not yet available from Medicare, it might be reimbursed by some commercial payers.

The COVID-19 pandemic spawned many programs designed to assist medical practices to stay afloat financially through the duration of the public health emergency. The terms and conditions of many of the various relief programs have changed since they were first introduced, and it often is a challenge to keep up with the latest rules. The Department of Health and Human Services (HHS) has now announced another round of Provider Relief Funding (PRF) and the terms of the Medicare Accelerated and Advanced Payment Program have recently been modified.

Quality Payment Program (QPP) participants can now obtain information about whether their practice will receive a positive, negative, or neutral Medicare fee schedule adjustment in 2021 based on the 2019 data they submitted. The Centers for Medicare and Medicaid Services (CMS) announced that clinicians who participated in the Merit-based Incentive Payment System (MIPS) in 2019 can access their performance feedback by logging in to the Quality Payment Program website. 

One of the fastest and easiest sources of emergency funding available to practices at the outset of the COVID-19 pandemic was the Medicare Accelerated and Advanced Payment Program.  As we recently reported, the initial timetable called for repayment of those advances to begin 120 days after the advance was made. Repayment was to be accomplished through reduction of Medicare reimbursements otherwise payable to the practice currently, until the full amount of the advance was repaid.