HAP Radiology Billing and Coding Blog

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.

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.

Quality Payment Program (QPP) participants can now obtain information about whether their practice will receive a positive, negative, or neutral Medicare fee schedule adjustment in 2021 based on the 2019 data they submitted. The Centers for Medicare and Medicaid Services (CMS) announced that clinicians who participated in the Merit-based Incentive Payment System (MIPS) in 2019 can access their performance feedback by logging in to the Quality Payment Program website. 

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.

Radiologists who perform venous ablation in a hospital outpatient department are now required to obtain prior authorization before performing such services on Medicare patients.  This new requirement became effective for services performed on or after July 1, 2020, and physicians were notified by letters from the Centers for Medicare and Medicaid Services (CMS) late in June.  The prior authorization requirement was included in the 2020 Hospital Outpatient Prospective Payment System (HOPPS) Final Rule, and encompasses the following procedures that might be performed by interventional radiologists:

In the final 2020 Medicare Physician Fee Schedule (MPFS), fee increases relevant to radiology overall outnumbered decreases.  However, many of those increases were insignificant changes of less than 1%.  There were 128 Professional Component (PC) codes decreased by more than 1%, with only 76 increased, while 430 Global codes increased by more than 1% and 346 Global codes decreased.  Here are the details: