The final rule for the 2019 Medicare Physician Fee Schedule (MPFS) issued by the Centers for Medicare and Medicaid Services (CMS) accepts many of the proposals made earlier this year but some are modified or delayed.

Here are the changes to Medicare rules that will apply to radiologists in 2019:

• Radiology Assistants (RA) may provide services under direct physician supervision. This means that the physician must be present in the office suite and immediately available to furnish assistance and direction throughout the performance of the procedure, but not necessarily in the room as was required under the previous “personal supervision” rule.
  
  
• The requirements for the documentation of E/M services were eased for 2019. These include elimination of the necessity to re-enter relevant information that is already contained in the medical record, whether entered by the physician or ancillary staff, as long as the record indicates that the physician has reviewed and updated the information as necessary.
  
  
• Hospital Outpatient Departments (HOPD) that are not grandfathered (that is, they were not in existence prior to November 2, 2015) will continue to be paid under the MPFS at a rate equal to 40% of the Hospital Outpatient Prospective Payment System (OPPS) rate for 2019.
  
  
• Telemedicine and Internet medicine updates: modern communication technology will be recognized by CMS by adding new CPT’s including a new virtual check-in brief-communication service code (G2012) and a new remote evaluation of recorded videos or images furnished by the patient code (G2010). Additional remote monitoring CPT’s and provider to provider phone, internet and electronic health record consultation CPT’s are under review for potential implementation beyond January 1, 2019.

Some of the proposals put forth by CMS were not accepted in the final rule.  They include the following:

• Good news of interest to interventional radiologists in particular is that CMS will not be applying a multiple procedure payment reduction (MPPR) of 50% to Evaluation and Management (E/M) visits performed on the same day as the related procedure. This maintains the opportunity to separately bill for consultations when appropriate. 
  
  
• The proposed collapsing of the payment for E/M services from 5 levels down to two levels was deferred until 2021.
  
  
• Revisions to the practice expense pricing for ultrasound and vascular rooms were proposed but will not be implemented in 2019.

Appropriate Use Criteria and Clinical Decision Support

Radiologists have been closely watching the developments surrounding the Appropriate Use Criteria (AUC) regulations.  The 2019 MPFS reaffirms that the requirement for ordering physicians to use AUC will begin in 2020, and that no payment penalties will be assessed until 2021.  The final rule provides some clarification of the ordering requirements, in that “when delegated by the ordering professional, clinical staff under the direction of the ordering professional may perform the AUC consultation with a qualified clinical decision support mechanism.”  

Independent Diagnostic Testing Facilities (IDTF) have been added as a setting that must comply with the AUC rule, along with a physician’s office, a hospital outpatient or emergency department, or an ambulatory surgery center. 

Ordering professionals will not be required to consult AUC under certain self-attested hardship circumstances, such as:

• Insufficient internet access
  
  
• Electronic health records (EHR) or clinical decision support mechanism (CDSM) vendor issues
  
  
• Extreme or uncontrollable circumstances (including natural or manmade disasters).

Analyzing the impact of the MPFS

The final conversion factor applied to the fee schedule is a 0.11% increase from the 2018 rate, and CMS estimates that the effect on diagnostic radiology will be neutral while interventional radiology will see a 2% increase in reimbursement.  Nuclear medicine, radiation oncology and radiation therapy centers are expected to see a 1% decrease.  However, the only way to really know the effect of fee schedule changes on your practice is to perform a volume  weighted analysis.  We will have more specific fee schedule information in an upcoming article, as well as updates on procedural and diagnosis coding. 

Conclusion

Although there are not quite as many revisions to Medicare payment policy for 2019 as in some years, it is always a good idea to keep abreast of the regulations that will affect your practice.  A CMS summary is available here.

The rules for the Quality Payment Program (QPP) are now included in the MPFS, and we will issue a separate review and summary of the QPP rules for 2019. Subscribe to our blog  and never miss an article!

Sandy Coffta is the Vice President of Client Services at Healthcare Administrative Partners.

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