HAP Radiology Billing and Coding Blog

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 Final Rule related to the No Surprises Act (NSA), issued August 26, 2022, clarifies and modifies the Independent Dispute Resolution (IDR) process but makes no changes to the patient protections and other provider obligations of the NSA, such as notifications and cost estimates for uninsured patients. The IDR process has been the most controversial part of the NSA, especially the stipulation of the Qualifying Payment Amount (QPA) as the primary determinant of reimbursement. The rule finalizes disclosures that insurance payers must share about the QPA and it addresses the information to be considered in the determination of payment under the IDR process.

Practice governance involves hands-on, day-to-day management and oversight, along with a strong basis in group culture and structure. The group’s structure and to some extent its culture is defined in its ownership and operating documents. Our article “Essential Steps to Smooth Practice Governance” that was initially published in the May/June 2022 (Volume 57, Issue 3) edition of the Radiology Business Management Association’s RBMA Bulletin offers a complete review of steps to help your practice operate smoothly through adherence to its foundation documents.

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.

Most updates to procedural and diagnosis coding become effective at the beginning of the year, but there are always a few mid-year changes that occur. In recent years, coding has changed to accommodate the COVID-19 public health emergency, and there are a few additions this year as well. Along with those, we’ll also add some reminders about topics that we’ve covered before.

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 shutdown of GE Healthcare’s Shanghai, China plant that began in April has caused a global shortage of the iodinated contrast media iohexol (GE’s Omnipaque ^TM). GE reports that it has returned to a 50% production rate, and they have shifted some production to a plant in Ireland, but they expect an 80% reduction in supplies through June. Alternative contrast agents such as iodixanol (GE’s Vispaque ^TM) and ioversol (Optiray^[1]) are becoming scarce as practices have shifted to using those products instead of iohexol. As of May 31, Omnipaque, Vispaque, and Ultravist (Bayer’s iopromide) have been added to the FDA’s list of drug shortages.

Will the requirement to use Clinical Decision Support (CDS) finally become a reality? The current timetable for the penalty phase of the AUC/CDS rule calls for it to begin on the later of January 1, 2023, or the January 1 following the end of the COVID-19 public health emergency (PHE). The PHE has just been extended another 90 days into July 2022, with no end in sight although there are some indications that it could end this year. One source reports that the Administration will give 60 days’ notice before ending the PHE. With this uncertainty, it would be wise for practices to be ready just in case!

On July 1, 2022, United Healthcare will begin to implement its Designated Diagnostic Provider (DDP) program for imaging facilities in certain states. According to United’s FAQ document, outpatient MRI/MRA, CT, PET, and nuclear medicine scans must be performed by a Designated Diagnostic Provider in order for members to have the lowest out-of-pocket cost. A member will pay more for services provided by non-DDP imaging facilities.