HAP Radiology Billing and Coding Blog

Physicians and other Eligible Clinicians (ECs) who are participating in MIPS under the MACRA rules governing Medicare payments will face requirements that differ depending on whether they are deemed to be “patient-facing” or not.  This determination will affect the Advancing Care Information (ACI) and Improvement Activities (IA) components, but not the Quality Performance component of MIPS. In this article, we’ll break-down the key considerations for radiology practices. 

By now everyone involved in billing Medicare for physician services should be aware of the new Quality Payment Program (QPP) that will be in effect for payments in 2019 based on data submitted in 2017.  The proposed rules for the new system were outlined in our recent article Medicare Quality Reporting Rules are Changing.  The final regulations that will govern the new system were recently issued, and radiology practices will benefit from preparing as early as possible to capture the data they will need to report under the new system.  ­

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Looking for our latest article on the 2018 updates?  Click here.

Congress has passed several Acts related to the Medicare payment system over recent years, the provisions of which will begin to take effect in 2017. These changes are embodied in the annual Medicare Physician Fee Schedule Final Rule for 2017 (MPFS) and the Hospital Outpatient Prospective Payment System Final Rule for 2017 (HOPPS).  In their initial review of the MPFS, the American College of Radiology (ACR) indicated that it “is pleased with several provisions within the rule.”

The Merit-Based Incentive Payment System (MIPS) is slowly being analyzed and absorbed by the medical community. This system, passed into law by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), will begin to take effect for physician reimbursement in 2019 but those payment adjustments will be determined by performance in various categories for services rendered in 2017.  Regulations governing the application of this law have now been finalized and savvy radiology practices can begin to prepare to comply with the new system.

Earlier this year CMS published its proposed regulations that would implement the MACRA law to revamp the Medicare physician payment system. On October 14^th, after consideration of over 4,000 comments about the proposed rules, CMS published the final rule that will govern the initial measurement period that begins January 1, 2017 for payment adjustments in 2019. 

Since its first appearance in the Medicare rules, the radiology community has been quarreling with CMS about the Multiple Procedure Payment Reduction (MPPR) on the professional component of certain diagnostic imaging services.  Finally, Congress has taken steps to mitigate the impact of this rule. 

Our first article in this series provided a list of questions to ask when evaluating a professional services Revenue Cycle Management (RCM) vendor for your radiology practice.  If your current RCM vendor cannot answer all of them positively, it’s time to look for a new vendor.  With a large number of RCM companies available in the market, how should you decide which one to choose?

In our previous articles in this series, we covered the top two reasons for radiology claims denials, Patient Eligibility Problems and Lack of Proper Authorization.  The third biggest reason for insurance claims denials is failure to document the medical necessity for the exam. Let’s take a look at this issue in detail so that your radiology practice can avoid such claims denials. 

Under regulations proposed earlier this year, physicians will face up to a 4% fee schedule reduction in 2019 for failure to meet the reporting requirements of the new Quality Payment Program in 2017. Now the Centers for Medicare and Medicaid Services (CMS) has announced that it is going to revise those proposed regulations to make it easier to avoid the negative adjustment and perhaps even earn a slight positive adjustment in 2019.  The final rules will be published around November 1, 2016 and will take effect on January 1, 2017.

The grace period during which Medicare would not impose penalties for less-than-specific coding under ICD-10-CM* is expiring on October 1, 2016.  The change from ICD-9 to ICD-10 diagnosis coding that took place on October 1, 2015 was a major adjustment for most physicians and their practice staff.  The Centers for Medicare and Medicaid Services (CMS) recognized some of the difficulties that were going to be faced in the transition, and in response they issued a document of guidance describing certain ‘flexibilities’ that would initially be allowed.