UPDATE: The Bipartisan-Bicameral Omnibus COVID Relief Deal signed on December 27, 2020, boosts the Medicare Physician Fee Schedule for a one-year 3.75% increase. This one-time increase adjusts for the effects of the physician fee schedule budget neutrality rules and is intended to provide relief to physicians during the COVID-19 public health emergency.
In addition, this legislation extends the “suspension of sequestration for Medicare fee-for-service payments by an additional three (3) months…adding on to the relief originally provided by the CARES Act.”
On September 1, 2020, the American Medical Association’s (AMA) Current Procedural Terminology (CPT) Editorial Panel approved changes to the CPT and HCPCS coding structure. Many of the new codes are being created as a result of bundling mandates or identified as potentially “misvalued” services. The changes were implemented on January 1, 2021.
As part of the annual mid-year review, the American College of Radiology (ACR) encourages radiology groups to implement new Category III codes. These new procedure codes affect irreversible electroporation (IRE) ablation and magnetic resonance spectroscopy (MRS).
Changes to Diagnostic Radiology
Screening CT of the Thorax
Codes 71250, 71260, 71270 are diagnostic. Also, a new CT of the thorax code will be available for reporting low-dose lung cancer screening.
The current HCPCS code G0297 was identified by the Centers for Medicare and Medicaid Services (CMS) as a high-value growth screen. It was subsequently referred to the editorial panel to establish a Category I CPT code to report low-dose CT for lung cancer screening.
Code 74425 – Diagnostic Radiology Procedures of the Urinary Tract will be revised, and a reciprocal parenthetical will be added clarifying that it can be reported with codes 50390, 50396, 50684, and 50690.
Codes 64400-64450 and 64455 (Introduction/Injection of Anesthetic Agent and/or Steroid into the Somatic Nervous System) will be added in the inclusionary parenthetical notes following Codes 77002 and 77003 – Fluoroscopic Guidance.
Ultrasound Follow-up Study
Code 76970 – Other Diagnostic Ultrasound Procedure has been referred to the CPT Editorial Panel for deletion due to low volume.
Percutaneous Core Needle Lung Biopsy
Code 32405 – Under Excision/Resection Procedures of the Lungs and Pleura will be deleted and replaced with a new code that bundles percutaneous core needle lung biopsy with imaging guidance when performed.
Specifically, Codes 32405 and 77012 were identified by the editorial panel as code pairs being performed together 75% or more of the time, and it was recommended that they are bundled.
Medical Physics Dose Evaluation
There will be a new Category I code in Radiology, Diagnostic Radiology (Diagnostic Imaging), Other Procedures subsection of the CPT to report the assessment and calculation of radiation dose, and the potential adverse iatrogenic effects received by the patient that may require follow-up observation or treatment.
This will be a technical component only code since a medical physicist most often performs this actual service.
Evaluation and Management
Evaluation and Management (E/M) Visits
The editorial panel has approved significant revisions to the E/M code descriptors. In fact, this is the first major overhaul to E/M reporting in over 25 years.
These changes include:
Eliminating history and physical exam for code selection and reducing the administrative burden
Allowing physicians to choose between medical decision-making (MDM) or total time to determine E/M
Modifying MDM criteria to affect the management of a patient’s condition
Following the lead of the CMS’ overall initiative to reduce unnecessary documentation, these changes will:
Ensure payment levels for outpatient E/M visit codes are resource-based,
Minimize the need for audits, and
More accurately reflect the services provided
As part of the new E/M code structure, there will be a new add-on code created to report additional provider time in 15-minute increments. This new add-on code will be reported with codes 99205 and 99215. Other changes include:
New patient code 99201 will be deleted
New patient codes 99202, 99203, 99204, and 99205, and established patient codes 99211, 99212, 99213, 99214, and 99215 codes will be editorially revised
Prolonged services codes 99354, 99355, and 99356 will also be revised to reflect these changes.
According to the AMA, “history and/or physical examination as a component for code selection will be eliminated; code level selection will be based on medical decision making (MDM) or time. There will also be changes in the definition of MDM and time when used with these codes. The E/M guidelines will be revised extensively to reflect these changes.”
NOTE: These codes were available on July 1, 2020.
Irreversible Electroporation (IRE) Ablation
Two new proposed Category III codes will be available for reporting irreversible electroporation (IRE) ablation, a new procedure that uses high voltage electrical impulses to treat cancer.
Magnetic Resonance Spectroscopy (MRS)
Four new Category III codes will be available to report magnetic resonance spectroscopy (MRS) for the determination and localization of discogenic spine pain (cervical, thoracic, or lumbar).
Additionally, the September/October 2020 issue of the ACR Radiology Coding Source will outline the new 2021 codes and descriptors relevant to radiology groups and practices.
The final Medicare rule also included telehealth provisions, which are now in place permanently. The speed with which telehealth was adapted would have made it hard to roll back, and fortunately, it won’t be at this time.
Looking through the radiology lens, the Appropriate Use Criteria (AUC) program and CDSM were conceived as a process that would complement and elevate the referring provider’s diagnostic practice, strengthen the Medicare patient experience, and reduce needless advanced image testing. The requirement impacts all physicians, APP, and facilities billing Part B Services to Medicare.
With the education phase extended through 2021, CMS has an approved list of vendors, of which Infinx is a participating member, that can provide the advanced automation to process certificates of compliance for CDSM. Active participation will ensure payment from Medicare after the mandatory implementation date of January 1, 2022.
With radiology reimbursement under siege, it’s important to stay up to date on pending changes and ensure that your coding game, whether in-house or part of a third-party partnership, runs smoothly.
Contact Infinx to learn more about discussing the benefits of a third-party coding and billing vendor to ensure accurate claims are submitted and revenue optimized.