HAP Radiology Billing and Coding Blog

A large metropolitan-area radiology group covers several departments within a hospital system. They have on-site staff daily at each location to handle all modalities, including sub-specialists to be sure pediatric, neuro, and body imaging are handled with the right expertise. They find that on some days a particular department is overloaded, while on the same day another department is slow. The subspecialists don’t always have enough work in their area to keep them busy. Lately, trying to hire enough hands in the tight radiology job market has become more and more difficult as well as costly. Unfortunately, the various hospitals do not all employ the same PACS even though they’re part of the same parent system. This group’s situation is not unique.

The Medicare Physician Fee Schedule (MPFS) was lowered for 2023 due to a cut of 2.08% in the Conversion Factor (CF) used to determine payment rates. We reported that the CF could have been reduced as much as 4.47% had Congress not intervened at the last minute to adjust it, along with waiving the 4% PAYGO reduction that was supposed to occur in 2023. The pricing of various procedure codes is also revised annually due to changes in practice expense assumptions, which generally affects the Technical Component (TC) more than the Professional Component (PC). Radiologists will therefore see a different overall result for services in a private office or imaging center than they will for hospital services.

Today's Quality Payment Program (QPP) began in 2006 as the Physician Quality Reporting Initiative (PQRI). It was a voluntary program that would earn participants a bonus payment of 2% of their prior-year Medicare reimbursements. Beginning with performance year 2013 (for payments in 2015) a penalty was imposed on those physicians who did not successfully report quality data. The 2016 performance year saw the initiation of the Value-Based Payment Modifier (VM) that allowed for upward, downward, or neutral payment adjustments in 2018 based on both the quality and cost of care delivery. In the first year the VM was applied, physicians with low cost and high quality earned an additional 9.78% over the basic Medicare fee schedule while the potential negative adjustment for not reporting, or not successfully reporting, was 6%. There was a lot of incentive to participate in the program at as high a level as possible!

Recently, a study by a joint task force of the American College of Radiology (ACR) and the Society of Interventional Radiology (SIR) pointed out the need for all diagnostic radiologists to have certain competencies in “Level 1” interventional procedures. Radiology Business reports that the aim of the task force was making recommendations for “broadening access to image-guided procedures for patient populations living in rural care settings or served by small IR practices.” According to the study abstract, “Radiology practices characterized as small and rural are challenged to recruit and retain interventional radiologists”, resulting in a failure to meet the needs of patients and others in these communities. Thus, having diagnostic radiologists with Level 1 competencies in small practice or rural health settings increases their ability to provide a wider range of needed services.

Once again this year, physicians are uncertain about the amount of reimbursement reduction they will suffer from Medicare cuts. If things are left unchanged, Medicare providers will face a reduction of approximately 8.5% across the board, without considering adjustments made to specific procedure codes. In recent years last-minute congressional action has mitigated the effect of certain statutory requirements.

When the 2023 Medicare Physician Fee Schedule (MPFS) was proposed earlier this year it projected a 4.42% cut to the conversion factor (CF), with radiology facing cuts of between 3 – 4% depending on subspecialty. The final rule moves the cut even deeper, with the 2023 CF set 4.47% lower than the 2022 CF.

Although we refer to the annual updates to the ICD-10-CM^[1] coding system as being for the coming year of 2023, they are effective and available for use on October 1, 2022.

The opportunities for non-physician providers (NPP) in radiology practices continue to expand. Recently the American College of Radiology (ACR) revised its CT and MRI facility accreditation criteria to allow NPPs to be able to directly supervise contrast administration. This mirrors the revised practice parameter for supervision of contrast administration that was previously adopted by the ACR. Note, however, that state licensure laws are the final authority that determine which services may be provided by NPPs.

Many radiologists prefer an independent practice model for a variety of reasons. Lifestyle and benefits (especially vacation and retirement) are often enhanced in a private practice. In the workplace, private practice offers more control over corporate culture along with the ability to structure the practice and its subspecialty focus in a way that best meets their patients’ needs. There is better opportunity for management of administrative and clinical time to accomplish research projects, journal articles, and continued professional growth. However, there are always challenges to maintaining practice independence, including staffing, consolidation, and legislative and environmental pressures.

Beginning in 2023, physicians will have the option to report under the Medicare Quality Payment Program (QPP) using MIPS Value Pathways (MVP) in lieu of the traditional reporting methods. MIPS, the Medicare Incentive-based Payment System, started gathering performance reports in 2017 and in 2019 the first Medicare payment adjustments were made based on that 2017 reporting. Eventually traditional MIPS reporting will be phased out, but the Centers for Medicare and Medicaid Services (CMS) has not proposed a timeline for doing so.