Radiologists, It’s Time to Call Your Member in Congress!

Your government is here to help. Under the guise of “Patients over Paperwork,” the Centers for Medicare & Medicaid Services has proposed a $5 billion boost to funding for reimbursement for care-related evaluation and management (E/M). Unfortunately the latest government effort to ease administration burdens on physicians will cost radiologists $450 million in one year alone, and $5.6 billion over the next decade.

The E/M code set encompasses the highest volume and highest expenditure of all the current code sets of the Medicare Physician Fee Schedule (MPFS). In 2017, MPFS reimbursements totaled over $47 billion, approximately 50 percent of all MPFS spending. Changes in E/M reimbursement may not seem at first glance particularly germane to the country’s 34,000 radiologists, since clinical encounter codes are not fundamental to what radiologists do. But these changes can make a huge difference in the incomes of radiologists for two reasons:

  1. Radiologists, especially interventional radiologists and radiation oncologists, bill under E/M with considerable frequency
  2. Requirements for changes in reimbursement to be budget-neutral will necessarily reduce reimbursement for the radiology specialty.

Early in 2018, CMS introduced its “Patients over Paperwork” initiative in response to the president’s executive order for all federal agencies to reduce the burden of paperwork. CMS believes that its extensive changes to coding and reporting requirements will save the medical profession 6,000 person-years of record keeping.

CMS is focusing on changes to office-based E/M codes. These codes will be limited to the location of the service, whether it is inpatient or outpatient, and the 1 to 5 scale for the level of complexity of the patient encounter. Level of complexity is determined by a mix of factors including time involved, patient’s history (new patient versus established patient), and medical decision-making. Radiologists know that documenting the elements to justify level of complexity is a considerable burden.

CMS is changing the five-level reporting system to a two-level reporting system. There will be no differences in payment or documentation requirements for levels 2 through 5. Reporting requirements will be lower. Payments for physician services will also be lower.

Understandably, the proposal has been criticized by specialists who see more complicated patients. The American Medical Association (AMA) has formed a CPT/RVS Update Committee workgroup to update the E/M codes. The AMA is seeking to develop its own methods to simplify coding, compliance, and documentation.

So what does the proposed changes to the E/M code mean for radiologists? Radiologists must keep informed of proposed code changes. They must make their voices heard to make sure that the new codes compensate the services radiologists provide.

Changes in coding could present radiologists with opportunities to enhance their income. For instance, new codes could reflect time spent in pre-procedure planning, post-procedure documentation, and imaging consultations. Input from radiologists can make sure that the services of radiologists to their patients are fully recognized and compensated.

And radiologists must address the issue of budget-neutrality. Under budget neutrality, if some E/M codes receive a bump in reimbursement, then other codes in the fee schedule must be adjusted. Radiology payments will be reduced. There will also be adjustments to technical components of reimbursement under the Indirect Practice Cost Index.

Radiologists may not be able to stop changes in reimbursement, but they can make their representatives aware of the impact of those changes on their practice. Educating Congress as to the consequences of this program is essential for another reason, if CMS is willing to make wholesale changes to the largest set of billing codes in the MPFS, they could also change coding, reporting, and payment structure for other code sets, such as radiology.  Only intervention by Congress will prevent these changes. The American College of Radiology urges Congress to waive the budget neutrality requirement. Only waiver of the budget neutrality rule will guarantee an equitable policy solution that penalizes no medical specialty.

Your voice makes a difference. The American College of Radiology reports that over 4,900 of its members have reached out to their members of Congress in the last month. Keep our momentum going. Visit the Radiology Action Network and click on the “TAKE ACTION” button.

Changes in CMS patient encounter codes will reduce reimbursement to radiologists by an average of $165,000 over the next decade. Radiologists need to call Congress now.