HAP Radiology Billing and Coding Blog

The flurry of legislative and regulatory activity over the past two months leaves us with our heads spinning!  Some funding, such as the $30 billion distribution of CARES^[1] Act Grant Funds, came to practices automatically and unexpectedly while other sources such as the Paycheck Protection Program through the Small Business Administration (SBA) have taken a lot of work with little result so far.  We reviewed as many federal programs as possible in our recent articles HHS Provider Relief Payment and Your Radiology Practice and What We Know - Federal Relief Programs That Could Assist Radiology Practices, and additional funding has been promised.  Practice managers have to be aware of the follow-up steps that are required following the receipt of money from any of these funding sources.

This article was updated on
April 16, 2020. 

Radiology practices are still trying to understand all of the implications of the payment sent automatically on April 10 by the Department of Health & Human Services (HHS).  Our article Update - CARES Act Relief Program Grant Fund Payments Delivered by HHS outlined the program, but many questions remain. 

When the CARES ACT was passed on March 27, details about the specific allocation of the $100 billion were not initially revealed. Today, April 10, $30 billion is currently being distributed to all Medicare providers in the first round of funding disbursement.

As of March 27, 2020, three pieces of legislation had been passed to address the economic impact of the COVID-19 coronavirus Public Health Emergency (PHE) and more legislation is expected.  Because they were hastily drafted and passed, technical corrections and interpretations are being issued regularly.  At the same time, certain agencies like the Centers for Medicare and Medicaid Services (CMS) are using the declared PHE to amend their own regulations to assist the healthcare community.  The legislation covers vast areas of the economy, but we will focus on those features that might be of interest to a medical practice or any other small business with fewer than 500 employees.

Our own Sandy Coffta, Vice President of Client Services, spoke with Aunt Minnie’s Brian Casey at the 2019 RSNA Annual Meeting in Chicago.  In the interview posted on auntminnie.com, Sandy mentioned some of the highlights that practices should be concerned about in the coming year. 

The Centers for Medicare and Medicaid Services (CMS) has released the annual changes to the Medicare Physician Fee Schedule (MPFS) in its Final Rule that contains not only adjustments to Medicare reimbursement but also revisions to the Quality Payment Program (QPP) for 2020 and beyond.   The MPFS Final Rule does not contain very many significant changes for the coming year, especially for radiology, but one of its provisions will have a far-reaching effect on radiology beginning in 2021. 

The “Patient Test Result Information Act”, or Pennsylvania Act 112 of 2018, will take full effect on December 23, 2019.  The Act was originally scheduled to begin in December 2018, but the imposition of citations and fines was delayed for one year.  During that time, many hospitals and radiology practices have implemented systems designed to help them comply with this law. 

Any physician who has read about the relatively high award in a recent medical malpractice lawsuit has to be thinking about how they can protect their own practice against a similar outcome from a missed communication with a patient or primary care physician.  In case you missed it, our recent article describes the lessons learned from this case. 

In our recent article we wrote about The Case for Maintaining an Independent Radiology Practice in the Face of Industry Consolidation.  A radiology practice that has served the community with high quality services over many years naturally has developed relationships that can be drawn upon to strengthen its position, and avoid what might otherwise seem to be the imperative to become absorbed by some larger entity.   Some of those existing relationships include the hospital served by the group, its referring physician community and neighboring radiology practices.

The recent award of $10 million in a medical malpractice lawsuit is noteworthy not only for the high amount of the award, but also for what can be learned from the case.  It highlights the consequences of poor patient communication and lack of appropriate follow-up.