Radiology Coding Alert

Reimbursement:

Brace for Hit to Radiology Reimbursement Following MPFS 2021 Final Rule

Plus, know what to expect for IDTFs and nuclear medicine.

If you’ve managed to work your way through the Medicare Physician Fee Schedule (MPFS) 2021 final rule, you’ll notice an underlying theme with respect to physician reimbursement: There’s less of it. Especially when it comes to surgical specialties, Medicare’s proposal to cut the conversion factor could have a profound impact on many practices’ bottom lines.

While some specialties that cater more toward office visits weathered the storm, the same can’t be said for radiology. Whether it’s diagnostic, interventional, nuclear medicine, or otherwise, you should plan on radiological services across the board taking a hit in 2021.

Read on for a glimpse into what kind of impact this final rule will have on the reimbursement landscape in 2021.

Check Out Shift in Conversion Factor

The bottom lines for numerous physician practices will take a hit, including radiology, thanks to the Centers for Medicare & Medicaid Services (CMS) aiming to cut the conversion factor (CF) by 10.2 percent. According to the final rule, Section 101(a) of MACRA changed the way the CF is calculated; plus, the office/outpatient evaluation and management (E/M) payment rate changes influenced the agency’s decision to lower the CF.

“With the budget neutrality adjustment to account for changes in RVUs [relative value units], as required by law, the final CY 2021 PFS conversion factor is 32.41, a decrease of 3.68 from the CY 2020 PFS conversion factor of 36.09,” CMS indicates.

Remember: The national CF is what you use when calculating payment when your providers perform surgical services such as nephrectomies, radical prostatectomies, and cystectomies etc., reminds Kelly D. Dennis, MBA, ACS-AN, CAN-PC, CHCA, CPC, CPC-I, owner of Perfect Office Solutions in Leesburg, Florida.

Do the math: The CF is the multiplier with the relative value units (RVUs) assigned to each procedure code, adjusted for geographic region, and calculated as the payment amount.

CMS offers a breakdown of the expected impacts from the payment rate change by specialty in the final rule. The details are in Table 90; however, annual changes, volume of patients, and types of services offered will also greatly affect Medicare revenues, says Miranda Franco, senior policy advisor with Holland & Knight LLP in Washington D.C., in a blog post.

See How Radiology Fares Among Other Specialties

Under the final rule, you can expect Medicare payments to decrease by 6 percent for general surgery, 6 percent for vascular surgery, 8 percent for thoracic surgery, and 8 percent for cardiac surgery compared to 2020 rates. Both diagnostic and interventional radiology should expect a combined 10 percent decrease. This was actually reduced from the proposed rule (11 percent) released earlier in 2020. Nuclear medicine will follow suit with a combined 8 percent decrease. Lastly, independent diagnostic testing facilities (IDTFs) should expect a combined 3 percent decrease in reimbursement.

These changes are in part due to radiology’s lower output of E/M visits as compared to specialties that utilize office and outpatient visits as one of their main sources of income. Generally speaking, those specialties that focus more exclusively on surgeries, rather than E/M visits, will see their revenue share decrease in 2021. The same concept applies to diagnostic radiology.

Public outcry: As expected, industry organizations are rattled by the major CF dip, especially in the midst of COVID-19 spikes. Backing up cash-strapped providers, the American Medical Association (AMA) urged Congress to get involved before the final rule is released later this year.

“The AMA appreciates that CMS will implement significant increases to the payment for office visits, based on recommendations on resource costs from the AMA/Specialty Society RVS Update Committee (RUC),” acknowledged AMA President Susan R. Bailey, MD, in a statement. “Unfortunately, these office visit payment increases, and a multitude of other new CMS payment increases, are required by statute to be offset by payment reductions to other services, through an unsustainable reduction of nearly 11 percent to the Medicare conversion factor.”

Bailey added, “For this reason, the AMA strongly urges Congress to waive Medicare’s budget neutrality requirement for the office visit and other payment increases. Physicians are already experiencing substantial economic hardships due to COVID-19, so these pay cuts could not come at a worse time.”

Surgeon stakeholders: “We support steps to expand access to care, but this rule takes one step forward and several steps back by disregarding patients’ needs and the surgeons who care for them,” said David B. Hoyt, MD, FACS, American College of Surgeons Executive Director in a statement with the Surgical Care Coalition. “The middle of a pandemic is no time for cuts to any form of health care, yet this final rule moves ahead as if nothing has changed. The health care system cannot absorb cuts of this magnitude.”

The final rule was published in the Federal Register on December 2, 2020 and is available at https://www.federalregister.gov/public-inspection/2020-26815/medicare-program-cy-2021-payment-policies-under-the-physician-fee-schedule-and-other-changes-to-part .