Medicare’s 2013 final rule to their Physician Fee Schedule has expanded to apply the multiple procedure payment reduction (MPPR) to physicians in the same group practice. Last year, the MPPR was enacted on the PC of advanced diagnostic services, paying the highest reimbursed CPT on a claim in full and reducing payments to subsequent CPTs by 25%. This was applied to each claim by individual NPI. Going forward, Medicare will begin applying this payment policy by group NPI instead of on an individual physician level, essentially closing this loophole. Specific to the professional component (PC), CMS defines a session as ‘when the studies are interpreted by the radiologist.’ CMS has failed to provide clear guidance on what constitutes as the “same session,” which is prompting speculation that date of service will be the governing rule for adjudicating claims for the professional component. APS will keep you informed as more information on these payment rules becomes available.
In working through the wide variety of billing arrangements, APS found payments that we had been missing.