HAP Radiology Billing and Coding Blog

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.

With passage of the Consolidated Appropriations Act, 2024 (CAA 24), we finally learned the rates physicians will be paid for Medicare services during the remainder of 2024. Effective when it was signed by the President on March 9, 2024 the CAA 24 contained several provisions that benefitted physician reimbursement:

We pay a lot of attention to government regulation in healthcare, especially the Medicare Physician Fee Schedule (MPFS) that influences reimbursement not only from Medicare, but also from other payers since many commercial contracts are tied to the MPFS. Although it is the object of most focus, the Centers for Medicare and Medicaid Services (CMS) is not the only agency that regulates healthcare.

The Centers for Medicare and Medicaid Services (CMS) announced its Medicare Physician Fee Schedule (MPFS) Final Rule for 2024, including provisions for both Medicare reimbursement and the Quality Payment Program (QPP).

During the COVID-19 Public Health Emergency, states were required to maintain enrollment of nearly all Medicaid enrollees as a condition of receiving a temporary 6.2 percentage point Federal Medical Assistance Percentage (FMAP) increase under the Families First Coronavirus Response Act (FFCRA). There was significant growth of national Medicaid enrollment figures due to this continuous Medicaid enrollment requirement, coupled with additional incentives for states to implement Medicaid expansion. The Kaiser Family Foundation estimates that the combination of Medicaid and CHIP (Children’s Health Insurance Program) enrollment has increased by over 23 million people between February 2020 and March 2023. However, when that continuous enrollment condition ended on March 31, 2023, Medicaid enrollment numbers started to decline. States had to resume normal operations, including restarting full Medicaid eligibility renewals and terminations of coverage for individuals who are no longer eligible. The full process could take up to a year, with the earliest removals from coverage having begun in April 2023.

For many radiology practices, the idea of a positive payment adjustment for participation in the Medicare Quality Payment Program (QPP) has been lost. Several factors have combined over the past few years to change the goal for radiology practices – it is now ‘penalty avoidance’ rather than a reward for reporting quality metrics. As we outlined in our recent review of the Medicare 2024 Physician Fee Schedule Proposed Rule, the QPP requirements for successful participation are going to become even stricter.

The Centers for Medicare and Medicaid Services (CMS) announced its proposed Medicare Physician Fee Schedule (MPFS) rules for 2024, including provisions for the Quality Payment Program (QPP). While not a done deal until the final rule is issued toward the end of the year, the Proposed Rule gives an indication of where CMS is headed with regard to payment policy. In recent history, even the Final Rule isn’t final because Congress has had to intervene to stave off significant reimbursement reductions. Here are the highlights of the 2024 Proposed Rule.