HAP Radiology Billing and Coding Blog

On January 1, 2022, practices will have to comply with the federal No Surprises Act (NSA) unless their state has a similar law already in effect. The federal legislation that was passed in December 2020 is intended to allow providers to receive a reasonable payment from insurers for services to non-network patients without putting those patients in the middle of a payment dispute. At the end of September, long-awaited regulations that will govern the details of its implementation were issued and were met with displeasure by healthcare providers. For example, the American College of Radiology^® (ACR^®) wrote in its detailed summary of the rule that it “is disappointed that the regulations violate the intent of the No Surprises Act (NSA) by making the Qualified Payment Amount (QPA) the primary determinant of physician payment rates in the independent dispute resolution process.”

In our recent article on reimbursement for using artificial intelligence (AI) in radiology, Sandy Coffta mentioned the possibility of new codes proposed by the American College of Radiology (ACR) and other imaging societies. One of those new codes was approved and released on July 1, 2021, for use beginning January 1, 2022. HCPCS^[1] Level II code 0691T (CPT^[2] Category III) will apply to the use of AI for automated analysis of existing CT studies for vertebral fracture(s), including assessment of bone density when performed, data preparation, interpretation, and reporting.

Based on revised recommendations from the US Preventive Services Task Force (USPSTF), the Centers for Medicare and Medicaid Services (CMS) is considering an adjustment to its reimbursement policy for LDCT Lung Cancer Screening. CMS expects to complete its decision-making process before February 2022. In the meantime, many commercial payers have already expanded coverage by adopting the new recommendations.

The No Surprises Act* will become effective January 1, 2022. This is the first federal regulation that is aimed at protecting patients from receiving unexpected bills from healthcare providers who are outside of their insurer’s network. Review our recent article for an overview of its provisions.

The radiology community is abuzz with talk of artificial intelligence (AI) systems that can assist physicians with image interpretation and perform other tasks. Like any new technology, it will take time before AI gains widespread acceptance due to the cost of implementation. This is analogous to the early-day PACS, where the benefits of efficiency had to be proven in order to justify the expenditure for such a costly system. Today almost all imaging is interpreted on computer systems … when was the last time anyone looked at a piece of film?

The Quality Payment Program (QPP) continues to be modified due to the COVID-19 public health emergency. The Centers for Medicare and Medicaid Services (CMS) recently announced some leeway for clinicians affected by the pandemic in 2020 and 2021.

The issue of patients receiving large, unexpected medical bills from hospitals and physicians has been widely publicized. This situation, known as surprise billing, arises when a hospital or physician provides medical care to a patient but is not participating in a patient’s insurance network. We have reported on the many states that have put legislation in place to try and mitigate the problem for their own residents, but now there will be a nationwide policy thanks to recent federal legislation.

When the Medicare Physician Fee Schedule (MPFS) Final Rule was published in December, it looked like radiology was facing a significant cut in Medicare reimbursement for 2021. Our article reported that professional component fees would drop 10-11% while global reimbursement would see a lesser impact. The Consolidated Appropriations Act, 2021 (CAA) rolled back those cuts at least for 2021, although the Medicare fee schedule for radiology will likely continue to be adjusted downward in the future as implementation of the revalued Evaluation and Management (E&M) services is fully phased in.

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 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.