Podiatry Coding & Billing Alert

CMS has begun penalizing reimbursements for non-digital imaging services.

By now, pretty much everyone knows that old-school, analog image acquisition and processing via film is inefficient and technologically outdated. Most podiatrists agree that it’s time to take their imaging systems into the digital age; and this is good, because CMS began penalizing analog and cassette-based imaging as of Jan. 1, 2017.

Pay hit: For chemical-based film, there’s a 20 percent penalty and 7 percent for cassette-based images. As reported in the Medicare Physician Fee Schedule, X-rays taken on film must begin using the FX modifier as of Jan. 1, 2017. CMS issued Change Request 9727, which reduces the technical component (including the TC portion of a global service) of X-ray imaging services provided using film.

The penalty for analog systems will mostly impact small and rural practices. “Most podiatrists have already converted to CR or digital, but many who bought cassette-based systems in the past years now have to upgrade again,” said Dr. Mark Dollard, DPM, DABPS, FACFAS of Loudoun Foot and Ankle in Sterling, VA. “They were trying to cost-effectively comply and had to pay up already. They just upgraded their systems, and now have to fork up more.”

Distinguish Between CR Imaging and Film Image Penalties

Beginning in 2018, practices using “computed radiology” (CR) where imaging is obtained via a cassette or imaging plate, the final rule “provides a 7 percent reduction in Medicare X-ray payments. CMS promises more details prior to the 2018 implementation date.

So, if you are using a digital X-ray system in 2017 and NOT obtaining your radiologic image on film, you do not have to do anything. You would bill as you previously have.

If you are still using film, you add the “FX” modifier to your global X-ray code. For example, CPT^® 73630 (Radiologic examination, foot; complete, minimum of 3 views)-FX-LT. Medicare will “automatically” reduce by 20 percent the technical component portion allowance for you.

The rationale behind the penalty is that digital images will allow for better communication and streamlining between healthcare systems.

Code choice: CMS also indicated that they would not publish an exhaustive list of applicable podiatry codes and intends to point to existing lists of physician fee schedule imaging services, as they believe that physicians and non-physician practitioners are in the best position to determine whether a particular imaging service is an X-ray taken using film.

“The MPFS amount cannot be greater than the Outpatient Prospective Payment System (OPPS) amount. MACs will compare the OPPS Facility and Non-Facility Payment fields to the MPFS Facility and Non-Facility amounts and use the lower amount,” CR 9727 says. “The FX modifier will reduce whichever of these two amounts applies by 20 percent.” The notice also states that the beneficiary is not liable for the FX modifier payment reduction.

Denial errors: “They want us to use the FX modifier so they can track it,” Dollard says. He notes that practices report sporadic denials when using the FX modifier, and that this was likely because some MACs just haven’t updated their systems. “Of course they make mistakes. But, if they wait too long to correct it, don’t hesitate to reach out to the CMS regional office for your area.”

To learn more about change request 9727, visit: https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM9727.pdf.

https://www.federalregister.gov/documents/2016/11/15/2016-26668/medicare-program-revisions-to-payment-policies-under-the-physician-fee-schedule-and-other-revisions.