The “Consolidated Appropriations Act, 2021” (CAA) is a sweeping piece of legislation that provides relief to individuals and businesses impacted by the COVID-19 public health emergency. Some of the relief provisions apply to all businesses, including medical practices, but it also contains several measures that specifically apply to medical practices.
The big news in Current Procedural Terminology[i] (CPT)® revisions for 2021 is the overhaul of the Evaluation and Management (E&M) section, reducing documentation requirements, and introducing new rules for determining the level of coding. These changes will affect interventional radiologists and radiation oncologists more than they will the day-to-day work of diagnostic radiologists. First, we will review the other non-E&M code changes affecting diagnostic and interventional radiology for 2021.
The Centers for Medicare and Medicaid Services (CMS) has released the final set of rules that will govern the Medicare payment system for the coming year, thereby affirming the drastic cut in radiology reimbursement for 2021 that was proposed earlier this year. There were few surprises in the Medicare Physician Fee Schedule (MPFS) Final Rule that were not contained in the proposed rule, other than a slight improvement in the fee schedule conversion factor and a change to the QPP Performance Threshold.
It’s been a while since we looked at the Paycheck Protection Program (PPP) and its loan forgiveness feature. Since the beginning of the program in April it has undergone some revision, many questions have been answered, and yet the answers to some questions remain unclear. Currently there is much discussion of when to file the application for loan forgiveness, with renewed concern about the taxation aspects of the PPP.
There are 490 new ICD-10-CM[i] codes that became effective on October 1, 2020, all of which are replacing existing codes. An additional 47 codes have been revised and 58 were deleted. Two new codes, U07.1 for COVID-19 and U07.0 for vaping-related disorders, took effect on April 1, 2020. They are contained in a new section of the guidelines, Chapter 22 “Codes for Special Purposes (U00 – U85)”.
Radiologists practicing in an imaging center or other non-hospital facility have a new tool available that will potentially allow them to recover some of the added costs related to safety precautions taken during the COVID-19 public health emergency. CPT code 99072 was added by the American Medical Association (AMA) Current Procedural Terminology (CPT®) Editorial Panel on September 8, 2020, with immediate effect. While payment for this code is not yet available from Medicare, it might be reimbursed by some commercial payers.
One of the fastest and easiest sources of emergency funding available to practices at the outset of the COVID-19 pandemic was the Medicare Accelerated and Advanced Payment Program. As we recently reported, the initial timetable called for repayment of those advances to begin 120 days after the advance was made. Repayment was to be accomplished through reduction of Medicare reimbursements otherwise payable to the practice currently, until the full amount of the advance was repaid.
The average cut of 11% in radiology reimbursement that is proposed by the Medicare Physician Fee Schedule for 2021 (MPFS) is the continuation of a trend that spans more than a decade.
The Centers for Medicare and Medicaid Services (CMS) has released their annual proposal for changes to the Medicare payment system for the coming year. 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 2021 and beyond.
Since the end of March we all have been focused on the impact of the public health emergency created by the COVID-19 pandemic, but slowly our attention is returning to the other ongoing issues of operating a practice. Let’s review some important topics that still exist on our radar screens.