HAP Radiology Billing and Coding Blog

Physicians’ Medicare reimbursement in the coming years will be impacted by their participation in CMS quality programs in 2014. Quality reporting programs such as PQRS, Meaningful Use and the new Value-Based Modification Program have allowed physicians to earn incentives for compliance with their requirements, but beginning in 2015 that carrot will become a stick. Medicare will apply penalties that reduce reimbursement for physicians that are eligible but do not participate in the programs. Payment reductions for 2015 have already been determined by participation in 2013, but there’s still an opportunity to take steps in 2014 to avoid a reduction in 2016 payments.

When the dust finally settled, we could see how the 2014 Medicare Physician Fee Schedule (MPFS) would impact radiology reimbursement, and results were mixed. Hospital-based services came out ahead while imaging centers generally took a big hit. Due to the many factors that contribute to the calculation of the final fee schedule, a weighted analysis will help you determine the actual impact on your practice.

CMS, the Centers for Medicare and Medicaid Services, has announced that it will begin full enforcement of rules concerning physician orders that have been in place since 2009. These rules will impact radiology billing. Beginning January 6, 2014, claims submitted for imaging services will be denied if they do not accurately report the name and NPI number of the ordering/referring provider.

In recent years, the Centers for Medicare and Medicaid Services (CMS) has broadened its use of the Multiple Procedure Payment Reduction (MPPR) methodology to reduce Medicare payments to physicians, but there may be situations where your practice can justify avoiding this payment reduction.

Physicians will begin to see their Medicare payments cut by 2% for services rendered beginning April 1st as the federal budget sequester takes effect. Their patients will still be responsible for co-insurance and deductibles at the same, pre-sequester level. For unassigned claims, reimbursements to beneficiaries would be subject to the 2% sequester reduction just like payments to physicians on assigned claims.

Radiology practices using teleradiology – servicing both hospitals and imaging centers – will have to consider whether they need to make any changes to their billing and reporting due to Medicare’s final Place of Service rules. CMS, the Centers for Medicare and Medicaid Services, has long been trying to establish rules for reporting the location of physician services. However, the rules have been delayed by questions and logistical problems that have been raised by those affected, primarily in the radiology community. Although many questions remain, CMS has issued what it considers to be its final set of rules, and they will become effective April 1, 2013. Practices should take a look at their service locations to see if they are operating in more than one payment locality and whether physicians are reading in locations other than where the patient was seen. If so, there is work to be done to prepare for the changes needed to submit radiology billing claims under the Medicare Physician Fee Schedule. 

Even though Congress has averted the across-the-board SGR fee schedule cut (26.5%) for another year, radiologists will take another 3% cut this year. This, in addition to expanding the PC MPPR of 25% for CT, MRI and ultrasound imaging to include other members of the group practice, means that there is no good news for radiologists this year.