Radiology Coding Alert

Adopt the FX modifier in X-rays using films.

Is your provider using X-ray films? If yes, this signals a cut in payment in 2017. “This is due to a push for US healthcare providers to move to digital radiography. Digital radiography has the benefit of easily transferring X-ray images to PACS systems, for quick physician interpretation, sharing and archiving,” says Michele Midkiff, CPC-I, RCC, an interventional and neuro-interventional radiology coding consultant in Mountain View, CA.

Transitioning to digital imaging: In an attempt to implement the provisions of Section 502(a)(1) of the Consolidated Appropriations Act of 2016, Centers for Medicare & Medicaid Services (CMS) has introduced modifier FX (X ray taken using film). This section titled “Medicare Payment Incentive for the Transition from Traditional X-Ray Imaging to Digital Radiography and Other Medicare Imaging Payment Provision,” emphasizes the need for providers to shift to digital radiography.

You will find this reform in the transmittal for change request (CR 9727) which was released last year. This transmittal is available at https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R3583CP.pdf. This transmittal clearly explains that you will face a 20 percent cut in payment for X-rays claims when your provider has used films during the procedure.

Here is what this CMS guidance means for radiology practices.

What imaging does this apply to? The rule applies to the technical component for X-rays taken using film.

How does the rule impact payment? Payment under the Physician Fee Schedule (PFS) for the technical component of X-rays taken with films will be reduced by 20 percent.

When does the payment rule apply? The reduced payments apply from Jan. 1, 2017. In 2017, you should submit claims for X-rays using films with modifier FX.

What will MACs assess? MACs will compare the facility and non-facility amounts for the Medicare Physician Fee Schedule (MPFS) and the Outpatient Prospective Payment System (OPPS). The MPFS cannot be greater than the OPPS component. MACs will use the lower amount and reduce the applicable amount by 20 percent. 

Add these messages: Beginning Jan. 1, 2017, you can use the following messages on claims in which the FX modifier reduction has been applied.

• Claim Adjustment Reason Codes (CARC) 237: Legislated/Regulatory Penalty. At least one Remark Code must be provided (may be comprised of either the NCPDP Reject Reason Code, or Remittance Advice Remark Code that is not an ALERT.) 
• Remittance Advice Remark Codes (RARC) N775: Payment adjusted based on X-ray radiograph on film. 
• Medicare Summary Notice (MSN) 30.1: The approved amount is based on a special payment method.

Resource: MLN Matters^® Number: MM9727 describes this “Payment Reduction for X-Rays Taken Using Film.” Read more at: https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM9727.pdf.