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.

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.

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.

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.

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.

Much has been written about the Paycheck Protection Program (PPP) loans and the complex rules for loan forgiveness, but there were other funding sources available early in the public health emergency that need to be revisited now.   Our article in April outlined the HHS Grant Funds and another article discussed the Medicare Accelerated & Advance Payments Program.

Since the end of March we all have been focused on the impact of the public health emergency created by the COVID-19 pandemic, but slowly our attention is returning to the other ongoing issues of operating a practice.  Let’s review some important topics that still exist on our radar screens.

We now have more concrete details about the revisions to the Paycheck Protection Program (PPP) that were outlined in our recent article following passage of the Paycheck Protection Program Flexibility Act (PPPFA).  The PPP Loan Forgiveness Application (SBA Form 3508) has been revised and a new simplified application (SBA Form 3508EZ) is also available, along with instructions, from the SBA website.