Articles by Sandy Coffta

This article explores current bills in legislation and regulations that could affect radiology practices in 2026 and beyond.

This article explores current bills in legislation and regulations that could affect radiology practices in 2026 and beyond.

The 2026 Physician Fee Schedule (PFS) Final Rule issued by the Centers for Medicare and Medicaid Services (CMS) contains very few changes from the Proposed Rule released in July.

The MPFS Final Rule was mostly unchanged from what was proposed a few months earlier. The conversion factors for 2026 Medicare reimbursement were proposed to be an increase of 3.3% to 3.8%, and the final figures came within that range but slightly lower by fractions.

Mammography remains one of the most critical areas of radiology practice, and one that is facing changes in reporting requirements and reimbursement policy.

The Medicare reimbursement rates for 2025 remain unchanged as a result of the Continuing Resolution (CR) passed by Congress and signed on March 15th.

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).

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.

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.

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.

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:

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.

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.

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.  

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. 

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.

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.

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.

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.

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.

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. 

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.