The Centers for Medicare and Medicaid Services (CMS) has released the final set of rules that will govern the Medicare payment system for the coming year, thereby affirming the drastic cut in radiology reimbursement for 2021 that was proposed earlier this year. There were few surprises in the Medicare Physician Fee Schedule (MPFS) Final Rule that were not contained in the proposed rule, other than a slight improvement in the fee schedule conversion factor and a change to the QPP Performance Threshold.
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.
In the final 2020 Medicare Physician Fee Schedule (MPFS), fee increases relevant to radiology overall outnumbered decreases. However, many of those increases were insignificant changes of less than 1%. There were 128 Professional Component (PC) codes decreased by more than 1%, with only 76 increased, while 430 Global codes increased by more than 1% and 346 Global codes decreased. Here are the details:
The Centers for Medicare and Medicaid Services (CMS) has released the annual changes to the Medicare Physician Fee Schedule (MPFS) in its Final Rule that contains not only adjustments to Medicare reimbursement but also revisions to the Quality Payment Program (QPP) for 2020 and beyond. The MPFS Final Rule does not contain very many significant changes for the coming year, especially for radiology, but one of its provisions will have a far-reaching effect on radiology beginning in 2021.
The Centers for Medicare and Medicaid Services (CMS) released their annual proposal for changes to the Medicare payment system for the coming year, and they also released new information about the existing mandate for the use of Clinical Decision Support (CDS) beginning in 2020. The Medicare Physician Fee Schedule (MPFS) Proposed Rule contains not only proposed adjustments to Medicare reimbursement but also proposed changes to the Quality Payment Program (QPP) for 2020 and beyond.
Our review of the proposed 2019 Medicare Physician Fee Schedule (MPFS) showed that 201 Professional Component (PC) codes and 213 Global codes were to be decreased by at least 1% in the Diagnostic Radiology 70000-series of CPT codes. In the final MPFS, only 46 PC codes were reduced by 1% or more, but 280 global codes were reduced by at least 1%. The number of codes expected to increase in payment did not change as dramatically, but in both PC and Global billing fewer codes were increased than we expected. Here are the details:
Each year there are revisions of Current Procedural Terminology[i] (CPT)® that will impact the way radiology practices code their procedures and, ultimately, how they are reimbursed for those procedures. The majority of CPT code changes in radiology for 2019 are for Interventional Radiology procedures. Those that pertain to diagnostic radiology are in ultrasound, MRI, and nuclear medicine. We’ll cover the diagnostic codes first, and then go into detail on the interventional coding changes.
With the publication of the Medicare Physician Fee Schedule (MPFS) Final Rule for 2019, which includes the Quality Payment Program (QPP) Final Rule, we can now review how radiologists can prepare to maximize their 2021 Medicare reimbursement through QPP participation in 2019. The QPP includes both the Medicare Incentive-based Payment System (MIPS) and Alternative Payment Model (APM) tracks. Since most radiology groups are currently participating in MIPS, we will focus on steps to take for successful participation in this program.
The final rule for the 2019 Medicare Physician Fee Schedule (MPFS) issued by the Centers for Medicare and Medicaid Services (CMS) accepts many of the proposals made earlier this year but some are modified or delayed.
The American College of Radiology (ACR) does a very thorough job of reviewing and commenting on proposed federal legislation such as the annual changes to the Medicare Physician Fee Schedule (MPFS). Their 59-page letter of September 10, 2019 to Seema Verma, Administrator of the Centers for Medicare & Medicaid Services (CMS), is available on the ACR website for radiologists to review in detail.