We’ve been watching the development of the Appropriate Use Criteria/Clinical Decision Support (AUC/CDS) requirement since 2014 when it was first included in the Protecting Access to Medicare Act (PAMA 2014). The latest Medicare Physician Fee Schedule (MPFS) confirms that the requirement to use CDS will begin this coming year on January 1, 2020, but imposition of any penalties associated with the referring physician’s failure to do so will be delayed until 2021. We are currently in a voluntary reporting period that runs through the end of 2019, so it’s a good time for every radiology practice to review where it stands with regard to this important Medicare regulation.
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.
Radiology groups who provide imaging services to patients in Pennsylvania should be aware of a new state law known as the “Patient Test Result Information Act,” or Pennsylvania Act 112 of 2018. Originally scheduled to begin on December 23, 2018, its implementation has been delayed for a year. In order to implement compliance with this new law, radiology groups and the facilities in which they practice will have to develop a system to monitor results and identify those that require a notice to be sent.
In our article Best Practices in Radiology Patient Billing, we identified a greater focus on practice billing processes as a critical element in improving patients’ satisfaction with the practice, and we encouraged practices to accept electronic payments. According to the InstaMed Trends in Healthcare Payments Eighth Annual Report 2017 released in May 2018, “Consumer loyalty is increasingly tied to the healthcare payments experience as 65 percent of consumers would consider switching healthcare providers for a better healthcare payments experience.”
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.
“If you think education is expensive, try ignorance.” Harvard President Derek Bok, et al.
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 term “Relative Value Units”, or RVU, is used frequently these days in a variety of contexts. RVUs form the basis for payment of physician fees by Medicare and other payers, and they can be used to measure physician productivity for a variety of purposes.
In September, we published the article Out-of-Network Balance Billing Laws Are Important for Radiologists to Be Aware Of about the New Jersey law that states patients receiving emergency or urgently needed services will not be required to pay any more than the deductible, copayment or coinsurance they would normally pay whether the hospital and/or its physicians are in-network or out-of-network with the patient’s insurance plan. Here are some more pieces of information we think you should know:
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.