HAP Radiology Billing and Coding Blog

The annual regulatory cycle of review, comment, planning and preparation has begun with the release of the Medicare Physician Fee Schedule (MPFS) Proposed Rule for 2018. In its preliminary review of those sections of the MPFS that will be of specific interest to radiology practices, The American College of Radiology (ACR) includes a statement that “the ACR is pleased with several provisions within the rule.”  They highlight the planned implementation of the Appropriate Use Criteria and Clinical Decision Support rules beginning January 1, 2019 and the proposal to leave the technical component of mammography services unchanged rather than lowering it by 50% as previously discussed. 

The Centers for Medicare and Medicaid Services (CMS) has issued its proposed revisions to the Medicare Physician Fee Schedule (MPFS) for 2017, thus beginning the annual cycle of review, comment, planning and preparation that goes along with this release.  Missing from this year’s proposed rule are provisions related to the Medicare quality reporting programs (PQRS, VM, MU-EHR*) that have been a large part of the rule in recent years. 

A variety of federal legislative activities during 2014 and 2015 contained rulings that will begin to affect Medicare reimbursement to physicians next year. Most recently, The Centers for Medicare and Medicaid Services (CMS) issued its Medicare Physician Fee Schedule (MPFS) Final Rule for 2016 that will govern its payments to physicians.  The overall impact of the final MPFS changes to radiology and radiation oncology practices compared with the proposed changes issued earlier this year, is estimated by CMS as follows:

The annual cycle of revising codes in the Current Procedural Terminology¹ (CPT)® has been completed with the issuance of the Medicare Physician Fee Schedule (MPFS) Final Rule for 2016, and radiology is one of the areas most affected by the changes.  The traditional radiology section of codes, 70010 – 79999, has 60 additions, revisions or deletions and there are even more when the Interventional Radiology (IR) surgical codes are considered. 

The American College of Radiology (ACR), Radiology Business Management Association (RBMA), and other similar provider advocacy organizations are busy analyzing and preparing responses to the Medicare Physician Fee Schedule (MPFS) Proposed Rule issued by the Centers for Medicare and Medicaid Services (CMS) recently.  According to the RBMA Washington Insider of July 14^th, “CMS estimates that if the provisions within the proposed rule are finalized, the overall impact of the MPFS proposed changes to radiology to be 0%, while interventional radiology would see an aggregate increase of 1%, radiation oncology a decrease of 3%, nuclear medicine a change of 0%, radiation therapy centers a decrease of 9%, and Independent Diagnostic Testing Facilities (IDTFs) a 1% increase.” 

The landscape of Medicare payment policy will be changing over the coming years as a result of actions taken in 2014 through the Medicare Physician Fee Schedule (MPFS) and the Protecting Access to Medicare Act (PAMA).  The MPFS for 2015 contained fewer changes to current payment policy than it did proposals deferred for future consideration.  The Protecting Access to Medicare Act of 2014 (PAMA) was initiated to avoid the significant Medicare payment reduction imposed by the Sustainable Growth Rate (SGR) provision in the Medicare law, but it also contained other provisions affecting payment under the Medicare program. 

According to the American College of Radiology (ACR), “The technical component for more than 200 imaging procedures will be cut by up to 55 percent in the final 2015 Medicare Physician Fee Schedule (MPFS) because of a decision to remove the direct practice expense of numerous film inputs that affected their reimbursement rates in favor of the cost of acquiring a desktop computer.”  The decreased reimbursement is sizable for such procedures as myelography, CTA and a variety of ultrasound studies.  The ACR’s analysis was released in their recent eNews article Analog to Digital Conversion to Cost Radiologists.  The article includes helpful impact tables showing the specific change in radiology reimbursement rates between 2014 and 2015 for each CPT code. 

The changes cited by the ACR are the result of Medicare’s attempt to recognize that most practices today use digital PACS technology rather than film.  They removed the costs associated with film production and storage, but replaced those costs with only the value of $2,501 to represent a typical radiology reading station.  No recognition was given to the overall cost of installing and maintaining the central PACS hardware and software.  The ACR reports that, as an example, CPT 76377 (3D Post-processing of tomographic modality) receives a 45.7% reduction for film-based costs offset by a gain of only 1.7% when the desktop computer is substituted.

The Medicare Physician Fee Schedule (MPFS) for 2015 sets the allowed fees for radiation therapy centers at a 1% increase, while radiation oncology professional services will remain unchanged.  The Centers for Medicare and Medicaid Services (CMS) had originally proposed drastic cuts in both the professional and technical components but instead elected to defer any decision on assumptions related to major practice expense categories while additional data is gathered.