Radiology Coding Alert

Plus: NCDs for PET scans may be removed.

The Medicare Physician Fee Schedule (MPFS) proposed rule for Calendar Year (CY) 2022 contains several changes suggested that could affect your radiology practice, if the proposal is finalized.

Additional highlights for the proposed rule include a decreased estimated conversion factor, removal of select National Coverage Determinations (NCDs), and the usual revised valuation of services.

Learn Which Diagnostic Services Would Be Subject to the OPPS Cap

CMS is proposing that certain services subject to the Multiple Procedure Payment Reduction (MPPR), as well as select procedures that “meet the definition of imaging” under section 1848(b)(4)(B) of the Social Security Act be subject to the Outpatient Prospective Payment System (OPPS) cap (URL: www.ssa.gov/OP_Home/ssact/title18/1848.htm). According to the Act, imaging services are defined as “imaging and computer-assisted imaging services, including X-ray, ultrasound (including echocardiography), nuclear medicine (including PET), magnetic resonance imaging (MRI), computed tomography (CT), and fluoroscopy, but excluding diagnostic and screening mammography.”

Therefore, CMS is proposing the following CPT^® codes and code families would be included on OPPS cap list:

• 0633T-0638T (Computed tomography, breast, including 3D rendering, when performed, …);
• 0648T-0649T (Quantitative magnetic resonance for analysis of tissue composition (eg, fat, iron, water content), including multiparametric data acquisition, data preparation and transmission, interpretation and report, …);
• 77X01-77X04 (Trabecular bone score (TBS), structural condition of the bone microarchitecture; using dual X-ray absorptiometry (DXA) or other imaging data on gray-scale variogram, calculation, …);
• 9111X (Gastrointestinal tract imaging, intraluminal (eg, capsule endoscopy), colon, with interpretation and report); and
• 933X0 (3D echocardiographic imaging and postprocessing during transesophageal echocardiography or transthoracic echocardiography for congenital cardiac anomalies for the assessment of cardiac structure(s) (eg, cardiac chambers and valves, left atrial appendage, intraterial septum, interventricular septum) and function, when performed)

Additionally, CMS proposes to accept all the RUC-recommended RVUs for the five new or revised codes that pertain to radiology.

Example: CMS is proposing an increased value of 1.59 for needle biopsy of lymph nodes (38505 Biopsy or excision of lymph node(s); by needle, superficial (eg, cervical, inguinal, axillary)), as the service “now involves larger tissue samples as well as a change in technology, and a change in the dominant specialty now reporting the service.”

CMS also proposes the RUC-recommended work RVUs of 0.20 for the trabecular bone score (TBS) code set (77X01-77X04).

Allow Local MACs to Make PET Scan Coverage Decisions

CMS is proposing removing NCD 220.6 for positron emission tomography (PET) scans. Removing the NCD from non-oncologic PET scans would defer coverage decisions to local Medicare Administrative Contractors (MACs). CMS believes that allowing local MACs to make the coverage decision would better serve “the needs of the Medicare program and its beneficiaries.”

Understand the Cause of a Decreased Conversion Factor for CY 2022

Heading into CY 2022, CMS is estimating a conversion factor of $33.5848, which is lower than the 2021 conversion factor of $34.8931. The decreased value is due in part to the adjustments in RVUs, redistributive effects of the CMS proposed clinical labor pricing update, and phasing in the implementation of supply and equipment pricing updates that were previously finalized.

If the CY 2022 rule is finalized, the proposed MPFS changes to radiology would have an overall impact of:

• Radiology: 2 percent decrease
• Interventional radiology: 9 percent decrease
• Nuclear medicine: 2 percent decrease
• Radiation oncology: 5 percent decrease
• Radiation therapy centers: 5 percent decrease

In a response to the release of the CY 2022 MPFS, the American Society for Radiation Oncology (ASTRO) states the proposed cut to radiation oncology services is “particularly troublesome given the experiences many practices have had over the last year, as they struggled to provide cancer treatments during the COVID-19 public health emergency (PHE)” (URL: www.astro.org/ASTRO/media/ASTRO/Daily Practice/PDFs/2022MPFS_ProposedRuleSummary.pdf).

Comment period open: CMS will accept comments on the proposed rule until 5 p.m. on September 13, 2021.

Review the full CMS Proposed Rule at >https://public-inspection.federalregister.gov/2021-14973.pdf?utm_medium=email&utm_campaign=pi+subscription+mailing+list&utm_source=federalregister.gov.