HAP Radiology Billing and Coding Blog

Complete documentation of any radiology procedure is the key to appropriate reimbursement. This is especially true for venous duplex Doppler ultrasound exams, where including fewer than the required number of elements for a complete procedure will result in reimbursement for a limited study.

In response to concern expressed across the spectrum of physicians and their representative organizations, the omnibus spending bill titled the Consolidated Appropriations Act, 2023 (CAA23) passed by Congress on December 23 rolled back a Medicare payment cut of 8.5%.  As a result, we estimate that the conversion factor will still be cut 2.08% for 2023. However, as we reported previously, many practices will feel a larger reimbursement reduction due to the annual valuation adjustments within the fee schedule.

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.

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.

The calculation of reimbursement under the Medicare Physician Fee Schedule (MPFS) is made up of three components, each of which can be adjusted during the annual rulemaking process. The one most discussed is the Conversion Factor (CF), which is the dollar amount applied to the table of Relative Value Units (RVU) to arrive at the reimbursement rate for each procedure; this is known as the National Medicare Fee. However, there is another factor, the Geographic Practice Cost Index (GPCI), that is applied individually to each payment locality across the country. This resulting fee is what is paid to the practice based on the location where the services are performed. The 2023 MPFS Proposed Rule proposes changes to all three components.

The Centers for Medicare and Medicaid Services (CMS) press release announcing the Medicare Physician Fee Schedule (MPFS) Proposed Rule for 2023 highlights expanded access to behavioral health services, Accountable Care Organizations (ACO), cancer screening, and dental care. Of these areas, cancer screening could be important to radiology practices, but the news was not good – CMS declined to include CT colonography coverage while it expanded coverage for traditional colonoscopy. The MPFS regulates the Medicare fee schedule payment provisions as well as the Quality Payment Program (QPP).

Radiologists at NYU Langone Medical Center have been creating video radiology reports in addition to their traditional text-based reports. The videos are intended for the patient, not the referring physician, and they are uploaded to the patient portal as they are completed. A team headed by Michael P. Recht, MD, studied the results, which became available online April 20 at the American Journal of Roentgenology. An example of a video report is included in NYU Langone’s NewsHub.

The federal No Surprises Act (NSA) has been in effect for a few weeks and many practices are just now beginning to make adjustments to accommodate the law. The level of pro-active involvement might be different for practices working solely in a hospital system from those with a private office or imaging center.

Now that the final Medicare conversion factor (CF) for 2022 of $34.6062 has been established, following passage of the Protecting Medicare and American Farmers from Sequester Cuts Act, we can analyze the real impact that radiology practices can expect this year. We reported recently that the final CF is a 0.82% reduction from the 2021 rate. However, the CF is not the only factor that affects the Medicare fee schedule. CMS annually revises the pricing of various procedure codes due to changes in practice expense, which generally affects the Technical Component (TC) more than the Professional Component (PC). Accordingly, radiologists will see a different overall result for services in a private office or imaging center than they will for hospital services.

The No Surprises Act (NSA) was designed to protect patients from receiving large medical bills from a physician or facility that does not participate in their insurance plan. It was to provide a mechanism whereby the providers could receive a payment from insurers that reflects a reasonable market price, with a dispute resolution process to be used when the parties were too far apart to reach an agreement. While this all sounds very reasonable and good for patients, it always seemed like the insurance companies could use the law as leverage to terminate existing agreements with providers who had negotiated high fee schedules and force them into lower-rate contracts. And that is exactly what is beginning to happen.