HAP Radiology Billing and Coding Blog

The ability to have radiologists work at locations remote from the patient exam site can be a great boon to efficiency and turnaround time. This practice has become more prevalent with the advent of faster network connections, and it has increased significantly since the COVID-19 pandemic when more people began working off-site. Compliant billing for remote reading services is not always as straightforward as normal on-site billing, and radiology practices must be aware of the requirements of each payer, most especially those of Medicare and other government programs.

With passage of the Consolidated Appropriations Act, 2024 (CAA 24), we finally learned the rates physicians will be paid for Medicare services during the remainder of 2024. Effective when it was signed by the President on March 9, 2024 the CAA 24 contained several provisions that benefitted physician reimbursement:

We pay a lot of attention to government regulation in healthcare, especially the Medicare Physician Fee Schedule (MPFS) that influences reimbursement not only from Medicare, but also from other payers since many commercial contracts are tied to the MPFS. Although it is the object of most focus, the Centers for Medicare and Medicaid Services (CMS) is not the only agency that regulates healthcare.

The Centers for Medicare and Medicaid Services (CMS) announced its Medicare Physician Fee Schedule (MPFS) Final Rule for 2024, including provisions for both Medicare reimbursement and the Quality Payment Program (QPP).

During the COVID-19 Public Health Emergency, states were required to maintain enrollment of nearly all Medicaid enrollees as a condition of receiving a temporary 6.2 percentage point Federal Medical Assistance Percentage (FMAP) increase under the Families First Coronavirus Response Act (FFCRA). There was significant growth of national Medicaid enrollment figures due to this continuous Medicaid enrollment requirement, coupled with additional incentives for states to implement Medicaid expansion. The Kaiser Family Foundation estimates that the combination of Medicaid and CHIP (Children’s Health Insurance Program) enrollment has increased by over 23 million people between February 2020 and March 2023. However, when that continuous enrollment condition ended on March 31, 2023, Medicaid enrollment numbers started to decline. States had to resume normal operations, including restarting full Medicaid eligibility renewals and terminations of coverage for individuals who are no longer eligible. The full process could take up to a year, with the earliest removals from coverage having begun in April 2023.

For many radiology practices, the idea of a positive payment adjustment for participation in the Medicare Quality Payment Program (QPP) has been lost. Several factors have combined over the past few years to change the goal for radiology practices – it is now ‘penalty avoidance’ rather than a reward for reporting quality metrics. As we outlined in our recent review of the Medicare 2024 Physician Fee Schedule Proposed Rule, the QPP requirements for successful participation are going to become even stricter.

The Centers for Medicare and Medicaid Services (CMS) announced its proposed Medicare Physician Fee Schedule (MPFS) rules for 2024, including provisions for the Quality Payment Program (QPP). While not a done deal until the final rule is issued toward the end of the year, the Proposed Rule gives an indication of where CMS is headed with regard to payment policy. In recent history, even the Final Rule isn’t final because Congress has had to intervene to stave off significant reimbursement reductions. Here are the highlights of the 2024 Proposed Rule.

Reimbursement under the Medicare Physician Fee Schedule (MPFS) has been consistently reduced for as many years as most of us can remember. Most recently, the 2023 payment rate was cut another 2.08% from the 2022 level, leaving the fee schedule 7.6% lower than it was in 1998 and 11.0% lower than it was in 2008.

A large metropolitan-area radiology group covers several departments within a hospital system. They have on-site staff daily at each location to handle all modalities, including sub-specialists to be sure pediatric, neuro, and body imaging are handled with the right expertise. They find that on some days a particular department is overloaded, while on the same day another department is slow. The subspecialists don’t always have enough work in their area to keep them busy. Lately, trying to hire enough hands in the tight radiology job market has become more and more difficult as well as costly. Unfortunately, the various hospitals do not all employ the same PACS even though they’re part of the same parent system. This group’s situation is not unique.

The Medicare Physician Fee Schedule (MPFS) was lowered for 2023 due to a cut of 2.08% in the Conversion Factor (CF) used to determine payment rates. We reported that the CF could have been reduced as much as 4.47% had Congress not intervened at the last minute to adjust it, along with waiving the 4% PAYGO reduction that was supposed to occur in 2023. The pricing of various procedure codes is also revised annually due to changes in practice expense assumptions, which generally affects the Technical Component (TC) more than the Professional Component (PC). Radiologists will therefore see a different overall result for services in a private office or imaging center than they will for hospital services.