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.
In our article Best Practices in Radiology Patient Billing, we identified a greater focus on practice billing processes as a critical element in improving patients’ satisfaction with the practice, and we encouraged practices to accept electronic payments. According to the InstaMed Trends in Healthcare Payments Eighth Annual Report 2017 released in May 2018, “Consumer loyalty is increasingly tied to the healthcare payments experience as 65 percent of consumers would consider switching healthcare providers for a better healthcare payments experience.”
The American College of Radiology (ACR) does a very thorough job of reviewing and commenting on proposed federal legislation such as the annual changes to the Medicare Physician Fee Schedule (MPFS). Their 59-page letter of September 10, 2019 to Seema Verma, Administrator of the Centers for Medicare & Medicaid Services (CMS), is available on the ACR website for radiologists to review in detail.
CMS, the Centers for Medicare and Medicaid Services, is constantly on the lookout for procedure codes that it feels do not reflect the current cost or complexity of practice in their valuation. The annual Medicare Physician Fee Schedule (MPFS) rule modifies many codes with varying degrees of impact to radiology practices.
Recently reported developments in federal health care policy could change the direction radiologists are taking to maintain maximum Medicare reimbursement.
In radiology, like all other medical specialties, proper documentation is critical to achieving appropriate reimbursement. If the proper terminology is no used or important descriptors are omitted from the radiology report, the physician may not get paid for the services he or she performed.
Our 2014 article "Interventional Radiology Meets Radiation Oncology – The y-90 Story” focused on the documentation requirements that will assist coders to maximize reimbursement for this complex procedure. Those documentation tips are still valid today. This update reviews the 2017 state-of-the-art in coding for y-90 procedures.
The annual regulatory cycle of review, comment, planning and preparation has begun with the release of the Medicare Physician Fee Schedule (MPFS) Proposed Rule for 2018. In its preliminary review of those sections of the MPFS that will be of specific interest to radiology practices, The American College of Radiology (ACR) includes a statement that “the ACR is pleased with several provisions within the rule.” They highlight the planned implementation of the Appropriate Use Criteria and Clinical Decision Support rules beginning January 1, 2019 and the proposal to leave the technical component of mammography services unchanged rather than lowering it by 50% as previously discussed.
New information has been provided by The Centers for Medicare and Medicaid Services (CMS) that will supplement our article An Update for Radiologists on Appropriate Use Criteria and Clinical Decision Support. We can now update you from the recent release of the “Proposed Medicare Physician Fee Schedule (MPFS) for 2018” and the “Proposed Rule for Quality Payment Program Year 2.”
Patients in rehabilitation facilities sometimes need imaging services that cannot be provided within the facility itself. Imaging centers willingly accept these patients but they can inadvertently fall into a collections quagmire if they aren’t aware of the Medicare rules related to skilled nursing facilities.