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Radiology Updates, Reminders, and Tips for MIPS

Coding

Radiology Updates, Reminders, and Tips for MIPS

The rules and requirements for success in the Medicare Quality Payment Program (QPP) are ever-changing, and it seems like each year brings a new challenge for practices to avoid a payment penalty or, hopefully, to earn a payment bonus. Most recently, CMS announced that the 2023 data submission deadline would be extended to April 15, 2024, due to the cyberattack at Change Healthcare in February, and that practices affected by the cyberattack could apply for an Extreme and Uncontrollable Circumstances (EUC) Exception. The EUC exception allows the applicant to request reweighting of any or all of the performance categories under the Merit-Based Incentive Payment System (MIPS).

 

While CMS has not specified the Change Healthcare cyberattack as a circumstance that would be acceptable for an EUC exception, some experts, like McDermott+Consulting, are reporting that it will qualify if it negatively impacted a provider's ability to participate in MIPS in 2024 by preventing them “from collecting MIPS data for an extended period of time.” Practices affected may consider completing the EUC application and choosing “Ransom/Malware” as the “Event Type” and confirming in the application that the ransom/malware event pertained to the Change Healthcare cyberattack. The EUC Exception application can be filed at any time during the year, until 8pm ET on December 31, 2024.

 

Alternatives to Traditional MIPS Reporting

 

Practices reporting in 2024 must obtain a score of at least 75 points to avoid a payment penalty in 2026; scores between 75 and 100 points will earn a positive payment adjustment in 2026. For the 2022 performance year, the mean score nationwide was 82.9 points, according to the CMS 2022 Quality Payment Program Experience Report. Unfortunately, radiology clinicians have a limited number of measures to choose from, which interferes with their ability to obtain a high score. One way to improve the pool of measures is to use a Qualified Clinical Data Registry (QCDR). A QCDR is operated by a vendor approved by CMS, often sponsored by specialty societies, such as the American College of Radiology (ACR). QCDR submission differs from the usual MIPS qualified registry submission in that QCDRs can submit non-MIPS measures, called QCDR measures, as well as MIPS quality measures.

 

Advantages for Small Practices

 

Because QCDRs charge a fee, they might be more suited to larger practices. Small practices, defined as those having 15 or fewer eligible clinicians billing under the same Taxpayer ID Number (TIN), have special advantages under the MIPS framework that can help them achieve a bonus without using a QCDR. The advantages for small practices include:

  • The ability to submit MIPS Quality Measures through claims reporting.
  • Three points are awarded for submitting:
    •  Quality measures without an available benchmark.
    •  Quality measures that do not meet case minimum or data completeness requirements.
  • Six (6) bonus points added to the quality performance category score for clinicians who submit at least one measure, either individually or as a group or virtual group.
  • Automatic reweighting of the Promoting Interoperability performance category to 0%, without the need to apply for a hardship exception.
  • Full credit in the Improvement Activities performance category for performing and attesting to either one high-weighted activity or two medium-weighted activities.

 

Possible New Quality Measures

 

CMS began a testing stage, in February 2024, for mammography measures that were created by Acumen, a policy research company with a focus on healthcare. The testing stage signifies an important first step toward official inclusion into the MIPS Quality Measures available for practices to report. In MIPS performance year 2024, there are no traditional MIPS measures for mammography. While the ACR-supported measure QMM18 (Use of Breast Cancer Risk Score on Mammography) is available for practices, it has no current benchmark.

 

The ACR reported that the following three outcome-related quality measures may become available for radiology groups to report on in the future:

 

  • Breast Cancer Screening Recall Rate Quality Measure (Outcome)
  • Breast Cancer Screening with an Eventual Breast Cancer Diagnosis: Positive Predictive Value 1 (PPV1) Quality Measure (Outcome)
  • Use of Biopsy After Diagnostic Follow-up with Eventual Breast Cancer Diagnosis: Positive Predictive Value 3 (PPV3) Quality Measure (Outcome)

 

According to the Quality and Safety Department of the ACR, the earliest that these proposed mammography measures will be finalized into MIPS and available for usage would be the 2026 performance year. We will not know until late 2024 whether or not the new measures were submitted to CMS.

 

Conclusion

 

With the Medicare Physician Fee Schedule constantly under the threat of annual reductions or small increases that do not keep up with inflation, avoiding a payment penalty for not fulfilling the minimum MIPS requirements is crucial. Practices must annually review the changes to the program and take advantage of any opportunity to improve their score.

 

Erin Stephens, CPC, CIRCC, is Sr. Client Manager of Education at Healthcare Administrative Partners.

www.hapusa.com

 

 

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Coding

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Dawning of a New Era: The Sun Rises on New E/M Standards in 2023 and Beyond

Coding

Dawning of a New Era: The Sun Rises on New E/M Standards in 2023 and Beyond:Well, the time is finally here! 2023 has ushered in a new standard for how we look at evaluation and management (E/M) services. Physicians, providers, coders, auditors, educators, and compliance professionals alike are finally able to utilize much more than the "bean-counting" methods set forth by the Centers for Medicare and Medicaid Services' (CMS) 1995 and 1997 ("95" and "97") E/M guidelines.
Is the End Really Near?

Coding

Is the End Really Near?:What is going on? We hear rumors that the end is near; well, that depends on what you are talking about - the end of what? The pandemic is not over; we are just making a transition. 
New Modifier Required on all Single Use Drugs

Coding

New Modifier Required on all Single Use Drugs:Attention providers and suppliers, there is a new modifier in town! Starting July 1, 2023, Modifier JZ - Zero drug wasted, will be required on all claims to attest there is no drug left over, if applicable. Meaning there is zero drug amount discarded, and there was no leftover drug administered to any patient.
2023 Coding Conundrums

Coding

2023 Coding Conundrums:We have our first bit of 2023 behind us, which means the first of the claims for the new year have been submitted.  Here's the $100,000 question: Are your claims paying appropriately with the 2023 Evaluation and Management (E/M) changes that have occurred?
Top 5 Takeaways From the CMS 2023 Final Rule: Conversion Factor, MIPS, Telehealth, E/M, and Refunds for Discarded Drugs

Coding

Top 5 Takeaways From the CMS 2023 Final Rule: Conversion Factor, MIPS, Telehealth, E/M, and Refunds for Discarded Drugs:As we walk into 2023 (or run depending on your enthusiasm for leaving 2022 behind), we are presented with the rules that will govern much of the healthcare industry's regulatory compliance standards and reimbursement guidelines. These rules are published in the Center for Medicare and Medicaid (CMS) Annual Final Rule, which was released on November 18, 2022 for the 2023 calendar year. 
Clean Claims: A New Year's Resolution You Can Keep

Coding

Clean Claims: A New Year's Resolution You Can Keep:Considering that coding errors can cost upwards of $20 billion per year in either delayed or permanently lost reimbursement,² clean claims are essential to the health of any medical organization's bottom line. 
World Cancer Day: Challenges of Working Toward a World Without Cancer

Coding

World Cancer Day: Challenges of Working Toward a World Without Cancer:World Cancer Day, started on February 4, 2000 at the World Summit Against Cancer (held in Paris), is an initiative of the Union for International Cancer Control (UICC). This international observance aims to ease the global burden of cancer by raising awareness and education about cancer and promoting more equitable access to care.  
Medicare Fee Schedule Changes In 2023

Coding

Medicare Fee Schedule Changes In 2023:The internet is ringing with the news of the CMS Updates Final rule for the 2023 Medicare Physician Fee Schedule. The finalized 2023 Medicare Physician Fee Schedule was announced by the Centers for Medicare & Medicaid Services (CMS) on November 1, 2022. 
Evaluation and Management 2023 Updates

Coding

Evaluation and Management 2023 Updates:Changes to 2023 Evaluation and Management (E/M) coding will impact CDM files, coding, documentation, charge capture processes, and various information systems.
A Long Time Coming: 2023 Changes to Inpatient Prolonged Service

Coding

A Long Time Coming: 2023 Changes to Inpatient Prolonged Service:It's been two years since CMS collaborated with the AMA to revamp Evaluation and Management (E/M) coding guidelines, including a rework of prolonged service codes in the office/outpatient setting.
How Does the Definition of

Coding

How Does the Definition of "Problem Assessed" Change in the 2023 E/M Guideline Updates?:In 2021, the AMA defined certain terms to facilitate better understanding and scoring for MDM. For the purposes of this article, we will focus more specifically on what is meant by "problems addressed" and what that means when scoring E/M services in the hospital inpatient and observation setting.
Lichen Sclerosus and Vaginal Lichen Planus

Coding

Lichen Sclerosus and Vaginal Lichen Planus:Lichen planus and lichen sclerosus are both idiopathic conditions that affect your skin, especially mucus membranes. The difference between lichen planus and lichen sclerosus is that lichen sclerosus rarely affects the mucous membranes in your mouth.
The Medicare Final Rule Confirms Big Payment Reduction for 2023

Coding

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.
2023 E/M Changes: What’s Coming?

Coding

2023 E/M Changes: What’s Coming?:When the American Medical Association (AMA) revised the Office/Other Outpatient Services codes in 2021, it was the largest change to E/M codes in decades.  The AMA has now turned its attention to the rest of the section, with massive changes coming January 1, 2023. 
2023 Procedure Coding Updates Are Just Weeks Away

Coding

2023 Procedure Coding Updates Are Just Weeks Away:Changes to the 2023 CPT code set include 102 new codes, 68 deleted codes, and 87 codes with revised long descriptions, as well as 36 new parent codes. 
Last Minute Congressional Action Reduces Medicare Fee Cuts For 2023

Coding

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.
The Role of the History and Examination in 2023 Evaluation and Management Services

Coding

The Role of the History and Examination in 2023 Evaluation and Management Services:While listening to the virtual AMA CPT/RBRVS Annual Symposium lecture by Gift Tee, BS, MPH, Director of the Division of Practitioner Services in the Hospital and Ambulatory Policy Group (HAPG) of CMS on the Update from Centers for Medicare and Medicaid Services (CMS), I was struck by something he said about the revisions to the coding and documentation framework for Evaluation and Management (E/M) Services for the 2023 CPT code descriptors.
A Long Time Coming: 2023 Changes to Inpatient Prolonged Services

Coding

A Long Time Coming: 2023 Changes to Inpatient Prolonged Services:It's been two years since CMS collaborated with the AMA to revamp Evaluation and Management (E/M) coding guidelines, including a rework of prolonged services codes in the office/outpatient setting. 
The Pain of Lichen Planus

Coding

The Pain of Lichen Planus:This article is written for all those people Joanne knows who are suffering from this autoimmune disease. It is painful and life altering in many ways. After research, we found that many practitioners, coders, and billers know little about this disease. We hope this article will help practitioners document and code this condition correctly, and direct patients with chronic LP for emotional support and refer appropriately to more experienced specialists for treatment.
Monkeypox: Coding and Documentation for U.S. Cases

Coding

Monkeypox: Coding and Documentation for U.S. Cases:Monkeypox is a rare disease caused by infection with the monkeypox virus. Monkeypox virus is part of the same family of viruses as variola virus, the virus that causes smallpox. Monkeypox symptoms are similar to smallpox symptoms, but milder, and monkeypox is rarely fatal. Monkeypox is not related to chickenpox.
Modifier FT

Coding

Modifier FT:As of January 1, 2022, CMS created a new modifier for an unrelated E/M visit during a postoperative period. It was revised as of April 1, 2022, quite possibly due to some questions on usage. Modifier FT is described as follows.
The No Surprises Act Final Rule Changes the IDR Process

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.
Coding and Documentation for Arterial Embolization

Coding

Coding and Documentation for Arterial Embolization:Arterial catheter embolization is an interventional radiology procedure that requires detailed documentation of the steps performed by the physician to maximize coding and reimbursement. The procedure places medications, embolic agents, or a radiopharmaceutical into a blood vessel to prevent abnormal bleeding, close off vessels, eliminate abnormal connections between arteries and veins, or to treat aneurysms or tumors.
Identifying Common Coding Errors for Lower Extremity Arterial Interventions

Coding

Identifying Common Coding Errors for Lower Extremity Arterial Interventions:Each day, thousands of patients are undergoing one or more therapeutic interventions, the most common ones being angioplasty, stent, and atherectomy of the lower extremity arteries to treat various forms of peripheral vascular disease. This article will highlight the most common coding errors to be on the lookout for when auditing these procedures.
Chutes and Ladders E/M Style

Coding

Chutes and Ladders E/M Style:We are all excited about the upcoming 2023 E/M changes, aren't we? Well, I can say, as a coder and auditor, I am! I've been in this E/M world for about 35 years.
2023 ICD-10-CM Code Changes

Coding

2023 ICD-10-CM Code Changes:In 2022, there were 159 new codes; the 2023 ICD-10-CM code update includes 1,176 new, 28 revised, and 287 deleted codes - a substantial change from last year. The 2023 ICD-10-CM codes are to be used for discharges from October 1, 2022 through September 30, 2023, and for patient encounters from October 1, 2022 through September 30, 2023.

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