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.
Regulatory Update – Radiology Faces Revenue Cuts In 2023 on December 2, 2022
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.
The Medicare Final Rule Confirms Big Payment Reduction For 2023 on November 15, 2022
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.
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.
Congress Responds to Lessen Medicare Cuts For 2022 on December 17, 2021
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.
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.
When the Medicare Physician Fee Schedule (MPFS) Final Rule was published in December, it looked like radiology was facing a significant cut in Medicare reimbursement for 2021. Our article reported that professional component fees would drop 10-11% while global reimbursement would see a lesser impact. The Consolidated Appropriations Act, 2021 (CAA) rolled back those cuts at least for 2021, although the Medicare fee schedule for radiology will likely continue to be adjusted downward in the future as implementation of the revalued Evaluation and Management (E&M) services is fully phased in.
How the Consolidated Appropriations Act Will Impact Radiology Practices on January 18, 2021
The “Consolidated Appropriations Act, 2021” (CAA) is a sweeping piece of legislation that provides relief to individuals and businesses impacted by the COVID-19 public health emergency. Some of the relief provisions apply to all businesses, including medical practices, but it also contains several measures that specifically apply to medical practices.
Medicare Delays Recoupment of Advances on September 10, 2020
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.
Radiology’s Declining Reimbursement Spans More Than A Decade on August 20, 2020
The average cut of 11% in radiology reimbursement that is proposed by the Medicare Physician Fee Schedule for 2021 (MPFS) is the continuation of a trend that spans more than a decade.