HAP Radiology Billing and Coding Blog

Beginning in 2019 the level of reimbursement from Medicare to many physicians will be determined in part by their performance in the Merit-based Incentive Payment System (MIPS).  Medicare will award a higher level of payment to those eligible clinicians and groups who report that they have successfully met certain criteria for Quality, Advancing Care Information, and clinical practice Improvement Activities.  MIPS is the successor program to the Physician Quality Reporting System (PQRS) and Meaningful Use of Electronic Health Records (MU-EHR) incentive programs, and CMS (the Centers for Medicare and Medicaid Services) has indicated that it will continue its practice of auditing the data submitted by practices just as they did under the earlier programs.  As this article in Healthcare IT News illustrates, the result of failing an audit will be non-payment of expected incentives (in the case of a pre-payment audit) or returning of funds already paid and possibly even federal sanctions depending on the severity of the infraction. 

In the August 4, 2017 edition of its Advocacy in Action eNews the American College of Radiology (ACR) reported on the Centers for Medicare and Medicaid Services (CMS) announcement regarding the manual application process for a significant hardship exception under the Advancing Care Information (ACI) category of MIPS. 

With the first year of the Merit-Based Incentive Payment System (MIPS) already well underway, the Centers for Medicare and Medicaid Services (CMS) began sending out MIPS Participation Status Letters in April. The letters were sent to each Eligible Clinician (EC) associated with a group Taxpayer Identification Number (TIN).  An EC can also check the Medicare Quality Payment Program (QPP) web site to determine his or her eligibility.  The letter and web site contain general information about participation in MIPS, along with email and telephone contact information that should be used if a provider feels his or her status is incorrect.

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. 

This is the third in our series of articles designed to help radiology practices prepare for the Merit-Based Incentive Payment System (MIPS). Previous articles covered the Quality Performance Category, which is the largest portion of the MIPS score, and the Advancing Care Information (ACI) Category.  Quality will initially account for at least 60% of the total MIPS score and ACI will account for up to 25% of the total score.  The Improvement Activities (IA) Category, originally called the Clinical Practice Improvement Activities in proposed regulations, represents 15% of the total score for 2017, the first year of MIPS participation.  The fourth element of MIPS, the Cost Category, has been reweighted to zero for 2017.

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. 

By now everyone involved in billing Medicare for physician services should be aware of the new Quality Payment Program (QPP) that will be in effect for payments in 2019 based on data submitted in 2017.  The proposed rules for the new system were outlined in our recent article Medicare Quality Reporting Rules are Changing.  The final regulations that will govern the new system were recently issued, and radiology practices will benefit from preparing as early as possible to capture the data they will need to report under the new system.  ­

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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...