When people are referred by their personal physician to a specialist, they usually see the specialist in his or her office for a consultation. Following the office visit, if the patient and physician deem a procedure to be appropriate, the procedure is scheduled in a facility such as an ambulatory surgicenter or hospital procedure room. Interventional radiologists, on the other hand, most often see their consultation patients at the time of the procedure in the hospital setting where the procedure will be performed, rather than in their own office. Changing this approach can yield benefits for the radiology practice, as well as for the patient.
Our 2014 article "Interventional Radiology Meets Radiation Oncology – The y-90 Story” focused on the documentation requirements that will assist coders to maximize reimbursement for this complex procedure. Those documentation tips are still valid today. This update reviews the 2017 state-of-the-art in coding for y-90 procedures.
As MACRA heads down the homestretch of its first implementation year, providers across all specialties are assessing the status of their practice and looking for guidance as to what the future holds. Understandably, concern and confusion remain. While most major players involved in healthcare delivery agree with the move to value-based compensation conceptually, the constant evolution of what is now the Quality Payment Program (QPP) has in many ways created more questions than it has answered. Specialty physician practices looking for certainties amidst the complexities should focus on this important factor: value-based payment models, in theory, have bi-partisan support. This is not expected to change despite the continuing ACA debate in Congress. Implementation delays and grace periods may indeed make it into ongoing legislation. However, proactive physician practices are realizing that the wait-and-see era is over. Maximizing reimbursements in the QPP in the years to come requires planning and implementing a compliance program right now.
A radiology practice that performs interventional procedures will want to be up to date on the use of documentation and coding techniques for Evaluation and Management (E&M) services. These CPT® codes in the 99xxx range are less commonly utilized in radiology practices. Identifying circumstances where E&M services are billable, and then properly documenting and coding for them, will require a collaborative effort between the interventional radiologist (IR) and his or her coding team.
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.
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.
New information has been provided by The Centers for Medicare and Medicaid Services (CMS) that will supplement our article An Update for Radiologists on Appropriate Use Criteria and Clinical Decision Support. We can now update you from the recent release of the “Proposed Medicare Physician Fee Schedule (MPFS) for 2018” and the “Proposed Rule for Quality Payment Program Year 2.”
Patients in rehabilitation facilities sometimes need imaging services that cannot be provided within the facility itself. Imaging centers willingly accept these patients but they can inadvertently fall into a collections quagmire if they aren’t aware of the Medicare rules related to skilled nursing facilities.
Radiologists considering the use of an outside service for final reads will have questions that include not only quality and cost but also the impact on the group’s relationship with its hospital and referring physician community. The answer will not be the same for every radiology practice. Here we present some of the pros and cons for consideration in the decision-making process.