HAP Radiology Billing and Coding Blog

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.

One of the tools available to assist with the collection of unpaid patient balances is to report the debt to a credit reporting bureau. While typically used as a last resort, it has had the effect of ultimately achieving collection when the patient applies for a loan that requires them to clear up the open balances shown on the credit report. While most physician groups are compassionate and are willing to work with their patients to avoid credit bureau reporting, they are required by insurance laws to pursue collection of patient co-payments and coinsurance. With patient deductibles, copayments and coinsurance increasing in many plans, loss of revenue to the practice through non-collection has become a bigger concern over recent years.

The workload of a radiology practice doesn’t diminish when one of the physicians is away, either on leave or due to termination, and one way to cope with the shortfall of staff is to use a temporary physician service. Knowing how to properly bill for those services is essential to maintaining cash flow in compliance with the regulations.

The Centers for Medicare and Medicaid Services (CMS) has announced a shift in its eligibility criteria for coverage of lung cancer screening using low-dose CT (LDCT), thus joining other payers in adopting recommendations made by the US Preventive Services Task Force (USPSTF).  In addition, CMS made other modifications to its eligibility criteria that will increase the ability of more people to obtain access to screening, effective February 10, 2022 with the posting of its Decision Memo.

The federal No Surprises Act (NSA) has been in effect for a few weeks and many practices are just now beginning to make adjustments to accommodate the law. The level of pro-active involvement might be different for practices working solely in a hospital system from those with a private office or imaging center.