HAP Radiology Billing and Coding Blog

Although we refer to the annual updates to the ICD-10-CM^[1] coding system as being for the coming year of 2023, they are effective and available for use on October 1, 2022.

The opportunities for non-physician providers (NPP) in radiology practices continue to expand. Recently the American College of Radiology (ACR) revised its CT and MRI facility accreditation criteria to allow NPPs to be able to directly supervise contrast administration. This mirrors the revised practice parameter for supervision of contrast administration that was previously adopted by the ACR. Note, however, that state licensure laws are the final authority that determine which services may be provided by NPPs.

Many radiologists prefer an independent practice model for a variety of reasons. Lifestyle and benefits (especially vacation and retirement) are often enhanced in a private practice. In the workplace, private practice offers more control over corporate culture along with the ability to structure the practice and its subspecialty focus in a way that best meets their patients’ needs. There is better opportunity for management of administrative and clinical time to accomplish research projects, journal articles, and continued professional growth. However, there are always challenges to maintaining practice independence, including staffing, consolidation, and legislative and environmental pressures.

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.