HAP Radiology Billing and Coding Blog

Just as you were done revising your practice systems and processes for Meaningful Use and MACRA/MIPS, a new Medicare mandate came along.  One of the biggest challenges for radiology practices right now is to be able to comply with the requirement that ordering physicians use a Clinical Decision Support Mechanism (CDSM) to consult Appropriate Use Criteria (AUC) when ordering MR, CT, PET and other specified nuclear medicine exams.  This rule has been on the books since 2014, but it will begin to be implemented in 2020 followed by the imposition of penalties in 2021.  This is not a voluntary bonus like Meaningful Use, or the avoidance of a small fee reduction under MIPS, but rather it means there will be NO payment to the radiologist for procedures performed without using the appropriate process.  

As MACRA heads down the homestretch of its first implementation year, providers across all specialties are assessing the status of their practice and looking for guidance as to what the future holds. Understandably, concern and confusion remain. While most major players involved in healthcare delivery agree with the move to value-based compensation conceptually, the constant evolution of what is now the Quality Payment Program (QPP) has in many ways created more questions than it has answered. Specialty physician practices looking for certainties amidst the complexities should focus on this important factor: value-based payment models, in theory, have bi-partisan support. This is not expected to change despite the continuing ACA debate in Congress. Implementation delays and grace periods may indeed make it into ongoing legislation. However, proactive physician practices are realizing that the wait-and-see era is over. Maximizing reimbursements in the QPP in the years to come requires planning and implementing a compliance program right now.    

Accuracy and completeness in radiology reporting has taken on an even higher level of importance in order to maximize Medicare reimbursement. The Quality Payment Program (QPP) under MACRA highlights the necessity to meet new quality performance standards.  While the benefits of structured reporting using templates have been discussed before, including in our article Reimbursement Benefits of Structured Radiology Reporting, reporting on quality measures under the QPP has to include very specific terminology in order to receive credit for the measure.  This is an ideal time for radiologists to begin to use standardized reporting across their practice to ensure that all of the critical elements of documentation are met. 

Physicians and other Eligible Clinicians (ECs) who are participating in MIPS under the MACRA rules governing Medicare payments will face requirements that differ depending on whether they are deemed to be “patient-facing” or not.  This determination will affect the Advancing Care Information (ACI) and Improvement Activities (IA) components, but not the Quality Performance component of MIPS. In this article, we’ll break-down the key considerations for radiology practices. 

The Merit-Based Incentive Payment System (MIPS) is slowly being analyzed and absorbed by the medical community. This system, passed into law by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), will begin to take effect for physician reimbursement in 2019 but those payment adjustments will be determined by performance in various categories for services rendered in 2017.  Regulations governing the application of this law have now been finalized and savvy radiology practices can begin to prepare to comply with the new system.

Earlier this year CMS published its proposed regulations that would implement the MACRA law to revamp the Medicare physician payment system. On October 14^th, after consideration of over 4,000 comments about the proposed rules, CMS published the final rule that will govern the initial measurement period that begins January 1, 2017 for payment adjustments in 2019. 

This year is the final reporting period under the now-familiar Physicians Quality Reporting System (PQRS). The Centers for Medicare and Medicaid Services (CMS) just announced proposed regulations that will govern new Medicare quality-reporting rules known as the Quality Payment Program (QPP) beginning in 2017.  This new system, which was enacted as part of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), comprises both the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs).  The final rules will be published later this year, but physicians can begin now to explore whether they want to join an APM or adapt to the MIPS reporting requirements. 

At Healthcare Administrative Partners, our mission is to educate practices on CMS Quality Programs and provide a path to optimized performance even in the most challenging markets. This is the final installment of our series of articles, “A Program for Successful PQRS Participation for Radiology Practices,” which was specifically designed to help you maximize reimbursement and reduce compliance issues under the Physician Quality Reporting System (PQRS).  So far we’ve covered...

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. 

A variety of federal legislative activities during 2014 and 2015 contained rulings that will begin to affect Medicare reimbursement to physicians next year. Most recently, The Centers for Medicare and Medicaid Services (CMS) issued its Medicare Physician Fee Schedule (MPFS) Final Rule for 2016 that will govern its payments to physicians.  The overall impact of the final MPFS changes to radiology and radiation oncology practices compared with the proposed changes issued earlier this year, is estimated by CMS as follows: