Radiology Coding Alert

Find out which radiology services have new RVUs.

The Centers for Medicare and Medicaid (CMS) Calendar Year (CY) 2022 Medicare Physician Fee Schedule (MPFS) contains several changes might affect your radiology practice’s reimbursement. CMS choosing to delay the start of the penalty phase for the Appropriate Use Criteria (AUC) program until 2023 or further could help radiology practices relax.

Additionally, the Centers for Medicare and Medicaid (CMS) has removed select National Coverage Determinations (NCDs), determined which imaging services are subject to the Outpatient Prospective Payment System (OPPS) cap, and provided adjusted relative value units (RVUs) for select CPT^® codes.

Read on to learn what the MPFS has in store for your radiology practice starting January 1. 

Find Out Which Imaging Services Meet the OPPS Cap

Earlier this year, CMS proposed subjecting certain diagnostic imaging services to the Multiple Procedure Payment Reduction (MPPR). Additionally, CMS proposed other 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.

CMS determined the following codes met the “imaging services” definition listed in the Act and should be subject to the OPPS cap:

• 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, …)
• 77089-77092 (Trabecular bone score (TBS), structural condition of the bone microarchitecture;…)
• 91113 (Gastrointestinal tract imaging, intraluminal (eg, capsule endoscopy), colon, with interpretation and report)
• +93319 (3D echocardiographic imaging and postprocessing during transesophageal echocardiography, or during transthoracic echocardiography for congenital cardiac anomalies, for the assessment of cardiac structure(s) (eg, cardiac chambers and valves, left atrial appendage, interatrial septum, interventricular septum) and function, when performed…)

The proposed codes listed above didn’t elicit any comments from the public, so CMS is finalizing the proposal.

Don’t Stress About Starting Your Practice’s AUC Program

Earlier this year, CMS proposed delaying the penalty phase of the AUC program until January 1, 2023, or the first of the year following the declared end of the COVID-19 PHE. This proposed postponement is due in part to receiving feedback regarding implementation and claims processing delays, as well as the impact of the PHE for COVID-19, which has affected beneficiaries, providers, and practitioners.

As the AUC program approaches the initial payment penalty phase indicated in the CY 2021 final rule, CMS is finalizing the start of the payment penalty phase to begin on January 1, 2023, or the first of the year following the declared end of the PHE for COVID-19, whichever occurs later. The wording in the final rule indicates CMS understands the “significant hardships” ordering professionals may be experiencing due to the COVID-19 PHE, and that AUC program exceptions will continue to be available.

According to CMS, “As significant hardship exceptions under the AUC program are self-attested, we did not propose, and decline to specify time frame parameters around experiencing an extreme and uncontrollable circumstances significant hardship due to the PHE for COVID-19.”

Learn Which CPT^® Codes Receive New RVUs

CMS proposed increasing the work RVU of CPT^® code 38505 (Biopsy or excision of lymph node(s); by needle, superficial (eg, cervical, inguinal, axillary)) to 1.59 after the RUC’s recommendation. The value adjustment is due to surveys that revealed the procedure now involves larger tissue samples, a change in technology, and a change in which specialty is reporting the service.

Following the public comment period, CMS is finalizing the proposed work RVU of 1.59 as well as RUC-recommended direct PE inputs without refinement for CPT^® code 38505.

For October 2020, RUC recommended the deletion of +74301 (Cholangiography and/or pancreatography; additional set intraoperative, radiological supervision and interpretation (List separately in addition to code for primary procedure)), but this recommendation received feedback from general surgery providers — who are the procedure’s primary provider. The providers indicated the code is still relevant, necessary, and should remain. CMS proposed the RUC-recommended work RVU of 0.21 for this code, which commenters received positively. As a result, CMS is finalizing the proposed work RVU for CPT^® code +74301.

For trabecular bone score (TBS) CPT^® codes 77089 (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, with interpretation and report on fracture-risk) and 77092 (…; interpretation and report on fracture-risk only by other qualified health care professional), CMS is finalizing the proposed value adjustments, which feature RUC-recommended work RVUs of 0.20. Additionally, CMS is finalizing the proposed direct PE inputs of 77089 and 77091 (…; technical calculation only) using a crosswalk approach to 71101 (Radiologic examination, ribs, unilateral; including posteroanterior chest, minimum of 3 views).

The final rule states CMS considers “most computer software and associated analysis and licensing fees to be indirect costs tied to costs for associated hardware that is considered to be medical equipment,” even though stakeholders have expressed concerns with the policy, as evolving technologies require more software and licensing fees while the hardware or equipment costs are minimal.

Removing NCDs to Help Medicare Beneficiaries

CMS is finalizing the proposal to remove NCD 220.6 Positron Emission Tomography (PET) Scans. Removing this NCD “better serves the needs of the Medicare program and its beneficiaries.” The final rule states many commenters supported the removal of this NCD and there weren’t any commenters opposing the proposal.

CMS proposed removing the NCD for PET scans for non-oncologic indications to provide local Medicare Administrative Contractors (MACs) with the discretion to make coverage determinations under section 1862(a)(1)(A) of the Social Security Act for beneficiaries. CMS also states in the final rule, “the NCDs listed at 220.6.1 through 220.6.20 will not be changed by removing this NCD.”

“Allowing local contractors the discretion to consider coverage will allow Medicare beneficiaries greater access to PET scans for non-oncologic indications,” says the American College of Radiology in their preliminary summary of the CY 2022 MPFS final rule (URL: www.acr.org/-/media/ACR/Files/Advocacy/2022-MPFS-Final-Rule-Preliminary-Summary.pdf).