HAP Radiology Billing and Coding Blog

The ability to have radiologists work at locations remote from the patient exam site can be a great boon to efficiency and turnaround time. This practice has become more prevalent with the advent of faster network connections, and it has increased significantly since the COVID-19 pandemic when more people began working off-site. Compliant billing for remote reading services is not always as straightforward as normal on-site billing, and radiology practices must be aware of the requirements of each payer, most especially those of Medicare and other government programs.

The Centers for Medicare and Medicaid Services (CMS) announced its proposed Medicare Physician Fee Schedule (MPFS) rules for 2024, including provisions for the Quality Payment Program (QPP). While not a done deal until the final rule is issued toward the end of the year, the Proposed Rule gives an indication of where CMS is headed with regard to payment policy. In recent history, even the Final Rule isn’t final because Congress has had to intervene to stave off significant reimbursement reductions. Here are the highlights of the 2024 Proposed Rule.

Once again this year, physicians are uncertain about the amount of reimbursement reduction they will suffer from Medicare cuts. If things are left unchanged, Medicare providers will face a reduction of approximately 8.5% across the board, without considering adjustments made to specific procedure codes. In recent years last-minute congressional action has mitigated the effect of certain statutory requirements.

When the 2023 Medicare Physician Fee Schedule (MPFS) was proposed earlier this year it projected a 4.42% cut to the conversion factor (CF), with radiology facing cuts of between 3 – 4% depending on subspecialty. The final rule moves the cut even deeper, with the 2023 CF set 4.47% lower than the 2022 CF.

With our first article posted in March 2020, we began a series designed to help you stay abreast of the many regulatory changes and funding opportunities that would help you get through the COVID-19 Public Health Emergency (PHE). The PHE is now scheduled to end on July 15, 2022, unless it is extended for another 90 days, but regardless of exactly when the PHE ends you will need to know what to expect. Some policies will end immediately, and others will end in some number of days later.

Now that the final Medicare conversion factor (CF) for 2022 of $34.6062 has been established, following passage of the Protecting Medicare and American Farmers from Sequester Cuts Act, we can analyze the real impact that radiology practices can expect this year. We reported recently that the final CF is a 0.82% reduction from the 2021 rate. However, the CF is not the only factor that affects the Medicare fee schedule. CMS annually revises the pricing of various procedure codes due to changes in practice expense, which generally affects the Technical Component (TC) more than the Professional Component (PC). Accordingly, radiologists will see a different overall result for services in a private office or imaging center than they will for hospital services.

The Medicare Physician Fee Schedule (MPFS) Final Rule for 2022 contained a 3.71% decrease in the Conversion Factor (CF), as we reported in our recent review of the rule. However, after lobbying by physicians and their representative organizations, Congress passed the Protecting Medicare and American Farmers from Sequester Cuts Act (the Act) that rolls back most of that cut and boosts the fee schedule that was contained in the MPFS Final Rule by 3%. We calculate that the CF for 2022 will therefore be $34.6062 instead of $33.5983, although the exact figure has not yet been released.

It seems that diagnostic imaging and radiology are often blamed for increasing the cost of healthcare, especially Medicare costs. Not so, says a recent study that was reported in Radiology Business on August 30, 2021.

On January 1, 2022, radiology practices and hospitals that perform certain imaging services for Medicare patients will be denied payment for those services unless they submit documentation that the ordering physician has consulted a Clinical Decision Support (CDS) system. This regulation was included a few years ago in Medicare rulemaking, but its effective date has been delayed several times. As of now, there is no reason to believe it will be postponed further, so practices that have not yet taken steps to install and implement a system have a narrow window of opportunity to get ready.

At around this time last year we were beginning to learn about the various ways medical practices could make use of federal programs to help keep them afloat through the COVID-19 pandemic. No one knew how long it would last. As time went on, we followed the changes to those programs, the new programs that became available, and the deadlines for action. Let’s review the latest federal legislation and also where each of last year’s relief programs stands today, especially the Medicare Payment Sequester that is a developing story.