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.
We are clearly in an era marked by the consolidation of healthcare services into fewer but larger providers, involving not only hospital systems but physician groups as well. Radiology practices are not immune to this trend. The study Radiology Practice Consolidation: Fewer but Bigger Groups Over Time published in April by the Journal of the American College of Radiology shows that practices consisting of 100 or more radiologists grew significantly between 2014 and 2018, while practices of fewer than 100 radiologists declined. There are many reasons local practices feel the need to become larger, but at the same time there is usually a lot of trepidation among the physicians about joining with another organization. Before jumping on the merger bandwagon, be sure you’ve considered the ways you can achieve your goals while remaining independent.
Radiologists are most likely not paying much attention to the Merit-based Incentive Payment System (MIPS) Cost category because no specific action is needed to report data, and usually radiology groups have little control over the cost attributed to a patient. The Centers for Medicare and Medicaid Services (CMS) has released a new MIPS resource on the Cost performance category that provides good information on this aspect of the MIPS scoring. This affords a good opportunity to review the Cost category and better understand its potential impact on your practice.
Proper coding of physician services is essential to efficient billing and the optimization of reimbursement from payers, including commercial and governmental entities. The CPT® codes issued by the American Medical Association (AMA) to describe physician procedures are supposed to be recognized as standards, but in practice they are not accepted equally by all payers. One example is CPT codes in the range 99241-99255 that describe consultation services. These are most often used by interventional radiologists, as described in our article Coding and Billing Considerations in Interventional Radiology.
Just as you were done revising your practice systems and processes for Meaningful Use and MACRA/MIPS, a new Medicare mandate came along. One of the biggest challenges for radiology practices right now is to be able to comply with the requirement that ordering physicians use a Clinical Decision Support Mechanism (CDSM) to consult Appropriate Use Criteria (AUC) when ordering MR, CT, PET and other specified nuclear medicine exams. This rule has been on the books since 2014, but it will begin to be implemented in 2020 followed by the imposition of penalties in 2021. This is not a voluntary bonus like Meaningful Use, or the avoidance of a small fee reduction under MIPS, but rather it means there will be NO payment to the radiologist for procedures performed without using the appropriate process.
It’s natural to want to compare one’s performance against others or to some standard. Radiologists often chat among themselves about the number of exams per year they read or maybe the number of RVU’s (Relative Value Units) they generate. While there are inherent problems with some of these comparisons as we outlined in our recent article Understanding the Value of RVUs in Radiology, measuring and monitoring productivity can be beneficial to a radiology practice and to the individual radiologist.
Earlier in March, we got the chance to sit down with Ted Burnes, Director of RADPAC (Radiology Political Action Committee) and Political Education at the American College of Radiology (ACR). Mr. Burnes is a native of the Philadelphia region and is a regular speaker at national Radiology Business Management Association (RBMA) and other radiology society meetings. His knowledge and passion for legislative updates and how they relate to the practice of radiology is a great resource that we are excited to share with our extensive readership.
You should evaluate your practice’s revenue cycle management method at least annually, whether you have an outsourced RCM vendor or if your billing and collection is done in-house.
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:
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.