HAP Radiology Billing and Coding Blog

The Centers for Medicare and Medicaid Services (CMS) announced that clinicians who participated in the Merit-based Incentive Payment System (MIPS) in 2018 can access their 2018 performance feedback by logging in to the Quality Payment Program website.   The information should confirm whether you or your practice will receive a positive, negative, or neutral Medicare fee schedule adjustment in 2020 based on the 2018 results.  According to a posting on the CMS website, 98% of eligible clinicians participated in MIPS for 2018, up from 95% in 2017, and 97% will receive a positive payment adjustment by virtue of exceeding the 15-point performance threshold. 

Radiologists are most likely not paying much attention to the Merit-based Incentive Payment System (MIPS) Cost category because no specific action is needed to report data, and usually radiology groups have little control over the cost attributed to a patient.  The Centers for Medicare and Medicaid Services (CMS) has released a new MIPS resource on the Cost performance category that provides good information on this aspect of the MIPS scoring.  This affords a good opportunity to review the Cost category and better understand its potential impact on your practice.

Medicare’s requirement that ordering physicians begin to use clinical decision support mechanisms (CDSM) when ordering certain advanced imaging examinations will take effect next year, and most radiology practices are gearing up to be ready.  Any CDSM will require a set of rules, or Appropriate Use Criteria (AUC), that will guide the decision-making process. 

The year 2019 marks the third reporting period under the Medicare Incentive-based Payment System (MIPS).  Radiology groups’ performance this year will determine their positive or negative Medicare fee schedule adjustment for payments in 2021, just as this year’s Medicare payment adjustment was determined by performance in 2017.

During 2016 we worked hard to provide our readers with information and advice that would allow them to maximize their performance under the Physician Quality Reporting System (PQRS) and therefore to maximize their reimbursement in 2018 under the associated Medicare Value-based Payment Modifier (VM).  The results have just been announced by the Centers for Medicare and Medicaid Services (CMS), and are available in a CMS Fact Sheet.

The annual regulatory cycle of review, comment, planning and preparation has begun with the release of the Medicare Physician Fee Schedule (MPFS) Proposed Rule for 2018. In its preliminary review of those sections of the MPFS that will be of specific interest to radiology practices, The American College of Radiology (ACR) includes a statement that “the ACR is pleased with several provisions within the rule.”  They highlight the planned implementation of the Appropriate Use Criteria and Clinical Decision Support rules beginning January 1, 2019 and the proposal to leave the technical component of mammography services unchanged rather than lowering it by 50% as previously discussed. 

Congress has mandated that the Centers for Medicare and Medicaid Services (CMS) move forward with quality-based programs and associated payment models. In 2015, the Medicare Access and CHIP Reauthorization Act (MACRA) was signed into law, expanding the Medicare quality-reporting programs that began as a voluntary incentive ten years ago with the original Physician Quality Reporting Initiative (PQRI).  Today it is more important than ever to embrace and maximize success in these programs and be ready to move ahead as they evolve. 

Participation in Medicare’s PQRS program is important to radiologists in order for them to maintain full reimbursement under the Medicare fee schedule, and to perhaps earn a higher level of payment in future years.  Radiologists providing services in Independent Diagnostic Testing Facilities (IDTFs) will not be able to participate in PQRS, according to a ruling described in the June 16, 2015 issue of the RBMA Washington Insider.  This most recent guideline issued by the Centers for Medicare and Medicaid Services (CMS) clarifies past guidance by stating, “After further review, CMS is announcing that EPs [eligible professionals] who provide services under an IDTF or an independent lab (IL) (and on behalf of services provided by that IDTF or IL) are not able to participate in PQRS.  Therefore EPs who provide services [billed] under an IDTF or IL will not receive the 2015-2018 PQRS payment adjustments for services associated with the IDTF or IL”.  This reverses CMS guidance issued as recently as March, 2015.