HAP Radiology Billing and Coding Blog

The Medicare reimbursement rates for 2025 remain unchanged as a result of the Continuing Resolution (CR) passed by Congress and signed on March 15. Thus, the downward spiral of Medicare reimbursement continues with physicians receiving nominally 2.83% less this year than in 2024. Radiology practices will see somewhat different results depending on their practice pattern, as we reported in our recent article analyzing the real impact of the Medicare Physician Fee Schedule (MPFS). We calculate that the Professional Component reimbursement would decrease 2.16%, while global reimbursement at an imaging center would decrease by 3.55%, both on a weighted-average basis.

The 2025 conversion factor (CF) that sets the overall rate for the Medicare Physician Fee Schedule (MPFS) was adjusted downward by 2.83% from the 2024 rate, to $32.3465 per Relative Value Unit (RVU) vs. $33.2875 per RVU. Several bills are pending in Congress that would mitigate the scheduled reduction, at least on a temporary basis, or perhaps to make more permanent corrections to the Medicare pricing formula. However, as of this writing none are in active discussion.

Every business in the country has to evaluate its obligation to comply with the Corporate Transparency Act (CTA) by December 31, 2024. The CTA was enacted as part of the Federal Anti-Money Laundering Act of 2020, and the regulations became effective on January 1, 2024. Many practices may already have complied with the law by either submitting the required information or by determining that they are exempt from filing. Failure to comply may invoke civil penalties of $591 per day along with criminal penalties of two years in prison and a $10,000 fine.

In April, 2020, the Federal Medical Assistance Percentage (FMAP) was increased so that states would receive extra funding for their Medicaid programs in support of the COVID-19 public health emergency. In exchange, the states promised to pause Medicaid eligibility checks so that more people would be able to continue to receive Medicaid benefits to get through the pandemic.

Ever since it became effective at the beginning of 2022, the No Surprises Act (NSA) has been the subject of legal challenges from the medical provider community. In particular, legal action was filed by the Texas Medical Association, et al (TMA), to challenge the Independent Dispute Resolution (IDR) methodology, which is viewed as more favorable to insurance claims payers and grossly unfair to physicians.

Practices that reported under the Merit-based Incentive Payment System (MIPS) of the Quality Payment Program (QPP) for 2023 can now get their performance score and find out how it will impact their Medicare reimbursement in 2025. The first step is to sign in to the QPP website to get your own practice’s results and review it for any discrepancies. The Centers for Medicare and Medicaid Services (CMS) has released the 2023 MIPS Performance Feedback FAQ’s as a guide to learning more about your practice’s performance.

The Centers for Medicare and Medicaid Services (CMS) has issued its proposal for payments in 2025 under the Physician Fee Schedule (PFS), and it contains an across-the-board 2.8% cut from the current 2024 payment rate. This reduction in payments continues a trend that has seen the Medicare fee schedule reduced nearly 10% over the past 10 years. Last year’s proposed rule (for 2024) contained a 3.36% cut that ended up being a 1.77% cut after Congressional intervention in March, and it is possible that similar action will occur again. The Conversion Factor (CF) in the 2025 Proposed Rule is $32.3562, compared with the $33.2875 currently in use.

The rules and requirements for success in the Medicare Quality Payment Program (QPP) are ever-changing, and it seems like each year brings a new challenge for practices to avoid a payment penalty or, hopefully, to earn a payment bonus. Most recently, CMS announced that the 2023 data submission deadline would be extended until April 15, 2024, due to the cyberattack at Change Healthcare in February, and that practices affected by the cyberattack could apply for an Extreme and Uncontrollable Circumstances (EUC) Exception. The EUC exception allows the applicant to request reweighting of any or all of the performance categories under the Merit-Based Incentive Payment System (MIPS).

At the April 14 – 17 Radiology Business Management Association (RBMA) PaRADigm Conference in Las Vegas, Rebecca Farrington and Sandy Coffta presented Positioning Your Radiology Group For Success. Their talk was a dive into a captivating exploration of real-world case studies from radiology groups that rode the waves of change. Whether the group soared to success or stumbled along the way, there's a story behind every strategic decision. Rebecca and Sandy unveiled the common pitfalls, the surprise twists, and the must-focus areas for crafting a winning strategy, including the informed choices that helped the groups navigate the intricacies of strategic planning.

The ability to have radiologists work at locations remote from the patient exam site can be a great boon to efficiency and turnaround time. This practice has become more prevalent with the advent of faster network connections, and it has increased significantly since the COVID-19 pandemic when more people began working off-site. Compliant billing for remote reading services is not always as straightforward as normal on-site billing, and radiology practices must be aware of the requirements of each payer, most especially those of Medicare and other government programs.