In early July, 2018, CMS released its proposed fee schedule for Calendar Year 2019. This proposed rule included a flattening out of reimbursement rates for Evaluation and Management (E&M), effectively reimbursing the same rate for level 2 services, as it allows for level 5 services. With one of the most common E&M services falling into the level 3 category, this should see an increase of payment for the average new or established visit. To accommodate longer and more complex appointments traditionally described and paid at higher rates as level 4 and level 5, the CMS has proposed add-on “G” codes to recognize additional relative resources for primary care visits and inherent visit complexity that require additional work beyond what’s accounted for in the single payment rate, along with another “G” code for prolonged face-to-face services. This looks like a win in reimbursement for everyone providing E&M services, until the proposed application of the Multiple Procedure Payment Reduction (MPPR) policy to E&M services.
The MPPR policy allows Medicare and other payers to reduce payment for certain services/CPTs, when services are performed on the same beneficiary on the same date of service. CMS looks at this as an efficiency, as it feels there are less resources involved in providing all services at once. Expanding the MPPR to E&M services would allow Medicare to pay the highest level code at the expected full reimbursement amount and the additional services/CPTs at 50% of the established rate. Depending on the scope and volume of patient facing services your radiology practice provides, this policy may be rather impactful to your bottom line. Perfecting the new E&M coding is paramount in ensuring you leave no money on the table, if these proposals are finalized this fall.
APS will continue to monitor the proposed 2019 Medicare Professional Fee Schedule and keep you up to date on what’s finalized and how it might impact your bottom-line. If you have any questions about this, please contact your Practice Manager.
In working through the wide variety of billing arrangements, APS found payments that we had been missing.