HAP Radiology Billing and Coding Blog

With passage of the Consolidated Appropriations Act, 2024 (CAA 24), we finally learned the rates physicians will be paid for Medicare services during the remainder of 2024. Effective when it was signed by the President on March 9, 2024 the CAA 24 contained several provisions that benefitted physician reimbursement:

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.

The Medicare Physician Fee Schedule (MPFS) was lowered for 2023 due to a cut of 2.08% in the Conversion Factor (CF) used to determine payment rates. We reported that the CF could have been reduced as much as 4.47% had Congress not intervened at the last minute to adjust it, along with waiving the 4% PAYGO reduction that was supposed to occur in 2023. The pricing of various procedure codes is also revised annually due to changes in practice expense assumptions, which generally affects the Technical Component (TC) more than the Professional Component (PC). Radiologists will therefore see a different overall result for services in a private office or imaging center than they will for hospital services.

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.

The calculation of reimbursement under the Medicare Physician Fee Schedule (MPFS) is made up of three components, each of which can be adjusted during the annual rulemaking process. The one most discussed is the Conversion Factor (CF), which is the dollar amount applied to the table of Relative Value Units (RVU) to arrive at the reimbursement rate for each procedure; this is known as the National Medicare Fee. However, there is another factor, the Geographic Practice Cost Index (GPCI), that is applied individually to each payment locality across the country. This resulting fee is what is paid to the practice based on the location where the services are performed. The 2023 MPFS Proposed Rule proposes changes to all three components.

Interventional radiology is among those specialties hit hard by the clinical labor practice expense cuts in the 2022 Medicare Physician Fee Schedule (MPFS). The proposed Physician Fee Schedule for 2022 contained an estimated 9% cut to interventional radiology (IR), due primarily to the revision of the practice expense component of the RVU calculation. The MPFS final rule brought the IR cut down to an estimated 5% after reconsideration of some of the methodology employed in calculating clinical labor costs. However, this is a blended figure that ignores the much larger effect on the global reimbursement for office procedures than on the professional component for hospital-based procedures.

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.

Coming a bit earlier in the month than usual, the release of the Medicare Physician Fee Schedule (MPFS) Final Rule for 2022 contains few changes from the rule proposed earlier this year. The Proposed Rule reported a 2022 Conversion Factor (CF) of $33.5848 per Relative Value Unit (RVU), but the Final Rule adjusts the figure slightly upward to $33.5983. This is a reduction of 3.71% from the 2021 CF of $34.8931. In addition to this cut, practices will see an additional 2% payment reduction when sequestration resumes on January 1, 2022.