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Does the Continuing Resolution Do Anything for Radiology?

The Medicare reimbursement rates for 2025 remain unchanged as a result of the Continuing Resolution (CR) passed by Congress and signed on March 15th. Thus, the downward spiral of Medicare reimbursement continues with physicians receiving nominally 2.83% less this year than in 2024. Radiology practices will see somewhat different results depending on their practice pattern, as we reported in our recent article analyzing the real impact of the Medicare Physician Fee Schedule (MPFS). We calculate that the Professional Component reimbursement would decrease 2.16%, while global reimbursement at an imaging center would decrease by 3.55%, both on a weighted-average basis.

The Continuing Resolution does contain two provisions related to physician practices. One is a simple extension through September 30, 2025, of the telehealth flexibilities that were scheduled to end on March 31, 2025. These include removing the geographic requirements and expanding the eligible originating sites for telehealth, expanding the practitioners eligible to provide telehealth services, and allowing audio-only telehealth services.

The other provision allows the MPFS to remain at its current level through September 30, 2025, by extending the 1.0 work floor factor that is used to calculate the geographic adjustment of the fee schedule. The Geographic Adjustment Factor is explained in more detail in our recent article, "What Else Is in the Medicare Proposed Rule for 2025?" Without the CR, some parts of the country would have seen their Medicare reimbursement reduced on April 1st by up to 2.7% on top of the 2.83% across-the-board cut.

While the CR failed to provide any increase in the MPFS, other legislation continues to be awaiting action in Congress. H.R. 879, the “Medicare Patient Access and Practice Stabilization Act of 2025,” would adjust the MPFS conversion factor upward by 6.62% resulting in a 3.79% increase over the 2024 rate. The bill, which has the bipartisan support of at least 143 co-sponsors, as it is written would take effect from April 1 to December 31, 2025, but its passage is not likely to occur before May 2025 as part of a budget reconciliation package.

Physician advocacy groups, such as the Radiology Business Management Association (RBMA), the American College of Radiology (ACR), and the Medical Group Management Association (MGMA) urge passage of the bill, which would provide a permanent solution to the downward fee schedule slide. The MGMA website has an easy link for anyone to contact their representatives about the importance of this legislation. We will continue to monitor any progress on the MPFS legislation, along with any other issues that will affect your reimbursement.

Sandy Coffta is Vice President of Client Services at Healthcare Administrative Partners. Coffta has over 17 years of experience in client relationship management, including reimbursement analysis, workflow optimization, and compliance education. www.hapusa.com

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What Is the Impact of the 2025 Medicare Fee Schedule Changes on Radiology Practices?:The 2025 conversion factor (CF) that sets the overall rate for the Medicare Physician Fee Schedule (MPFS) was adjusted downward by 2.83% from the 2024 rate, to $32.3465 per RVU vs. $33.2875 per Relative Value Unit (RVU).

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Possible Loss of Screening Coverage Will Impact Radiology Practices:In April 2020, the Federal Medical Assistance Percentage (FMAP) was increased so that states would receive extra funding for their Medicaid programs in support of the COVID-19 public health emergency. In exchange, the states promised to pause Medicaid eligibility checks so that more people would be able to continue to receive Medicaid benefits to get through the pandemic.

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Medicare Finalizes 2025 Fee Schedule Cut:Absent any last-minute Congressional action, physicians will suffer a 2.83% fee schedule reduction for 2025. This is slightly more of a cut than had been predicted in the Medicare Physician Fee Schedule (MPFS) Proposed Rule that was issued in July. As we reported in our analysis of the Proposed Rule, this reduction in payments continues a trend that has seen the Medicare fee schedule reduced by nearly 10% over the past 10 years.

Practice Management

Regulatory Issues Facing Radiology Groups in 2024:We pay a lot of attention to government regulation in healthcare, especially the Medicare Physician Fee Schedule (MPFS) that influences reimbursement not only from Medicare but also from other payors since many commercial contracts are tied to the MPFS. Although it is the object of most focus, the Centers for Medicare and Medicaid Services (CMS) is not the only agency that regulates healthcare.

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How Are Radiology Practices Impacted by Annual Changes to the Medicare Physician Fee Schedule?:With passage of the Consolidated Appropriations Act, 2024 (CAA 24), we finally learned the rates that physicians will be paid for Medicare services during the remainder of 2024. Effective when it was signed by the president on March 9, 2024, the CAA 24 contained several provisions that benefitted physician reimbursement:

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Why Support for H.R. 2474 Is Important to Your Radiology Practice:The Strengthening Medicare for Patients and Providers Act (H.R. 2474) would modify the way the Medicare Physician Fee Schedule (MPFS) is calculated and adjusted each year. The basic system of determining Relative Value Units (RVU) would not change, but the annual adjustment of the Conversion Factor (CF) would more closely reflect the actual economic factors that affect physicians' practices.

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Medicare Proposed Rule for 2024 Will Not Improve Radiology Reimbursement :The Centers for Medicare and Medicaid Services (CMS) announced its proposed Medicare Physician Fee Schedule (MPFS) rules for 2024, including provisions for the Quality Payment Program (QPP). While not a done deal until the final rule is issued toward the end of the year, the Proposed Rule gives an indication of where CMS is headed with regard to payment policy. In recent history, even the Final Rule isn’t final because Congress has had to intervene to stave off significant reimbursement reductions. Here are the highlights of the 2024 Proposed Rule.

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How Can Radiology Networking Improve Your Practice?:A large metropolitan-area radiology group covers several departments within a hospital system. They have on-site staff daily at each location to handle all modalities, including sub-specialists to be sure pediatric, neuro, and body imaging are handled with the right expertise.

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What Is the Impact of the 2023 Medicare Fee Schedule on Your Radiology Practice?:The Medicare Physician Fee Schedule (MPFS) was lowered for 2023 due to a cut of 2.08% in the Conversion Factor (CF) used to determine payment rates. We reported that the CF could have been reduced as much as 4.47% had Congress not intervened at the last minute to adjust it, along with waiving the 4% PAYGO reduction that was supposed to occur in 2023.

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The Medicare Final Rule Confirms Big Payment Reduction for 2023:When the 2023 Medicare Physician Fee Schedule (MPFS) was proposed in early 2022, it projected a 4.42% cut to the conversion factor (CF), with radiology facing cuts between 3-4% depending on subspecialty. The final rule moves the cut even deeper, with the 2023 CF set 4.47% lower than the 2022 CF.

Practice Management

Expanded Authorization for Non-Physician Providers:The opportunities for non-physician providers (NPP) in radiology practices continue to expand. Recently, the American College of Radiology (ACR) revised its CT and MRI facility accreditation criteria to allow NPPs to be able to directly supervise contrast administration.

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Last Minute Congressional Action Reduces Medicare Fee Cuts For 2023:In response to concern expressed across the spectrum of physicians and their representative organizations, the omnibus spending bill, titled the Consolidated Appropriations Act, 2023 (CAA23), passed by Congress on December 23, rolled back a Medicare payment cut of 8.5%. As a result, it is estimated that the conversion factor will still be cut 2.08% for 2023. However, as reported previously, many practices will feel a larger reimbursement reduction due to the annual valuation adjustments within the fee schedule.

Billing

Regulatory Update: Radiology Faces Revenue Cuts in 2023:Once again this year, physicians are uncertain about the amount of reimbursement reduction they will suffer from Medicare cuts. If things are left unchanged, Medicare providers will face a reduction of approximately 8.5% across the board, without considering adjustments made to specific procedure codes.

Coding

The No Surprises Act Final Rule Changes the IDR Process:The Final Rule related to the No Surprises Act (NSA), issued August 26, 2022, clarifies and modifies the Independent Dispute Resolution (IDR) process but makes no changes to the patient protections and other provider obligations of the NSA, such as notifications and cost estimates for uninsured patients.

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What's In Store for Radiology In The 2023 Medicare Proposed Rule?:The Centers for Medicare and Medicaid Services (CMS) press release announcing the Medicare Physician Fee Schedule (MPFS) Proposed Rule for 2023 highlights expanded access to behavioral health services, Accountable Care Organizations (ACO), cancer screening, and dental care.

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Sandy Coffta

Vice President of Client Services at Healthcare Administrative Partners

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