September 2022 Ebrief

2023-Another year of proposed Medicare cuts while the inflation and labor cost continue to skyrocket. In 2023, CMS estimates an overall impact of the MPFS proposed changes to radiology to be a 3% decrease, a 4% decrease for interventional radiology, a 3% decrease for nuclear medicine, and a 1% decrease for radiation oncology and radiation therapy centers if the provisions within the proposed rule are finalized. Click Here

Flagging survey findings for public scrutiny, the ACR says insurers using primary-care rates to pay specialists may be doing so in violation of the No Surprises Act. Click Here

Many of our radiology practices have invested time and resources in the never-ending quest to maximize our MIPS performance and experience the promised double digit Medicare fee adjustments highlighted in the program. The disappointing reality is that the maximum adjustments experienced since 2017 have been underwhelmingly capped at less than 2%. An amount that doesn’t even offset the mandatory 2% sequestration adjustment in place since 2013. The reason for this may lie in the fact that a high percentage of practices are hitting the top scores which, in turn, dilutes the incentive monies available in this budget neutral program.As a result, the measures become more difficult or capped to a level that does not provide the points necessary to obtain the top 100 pts.

As many of you know, the MIPS program experienced fundamental changes in the 2022 performance year. Most notably, the methodology for establishing performance thresholds, which dictate reimbursement adjustments for most fee schedule services, fundamentally shifted from an arbitrary process to one based on historical performance benchmarks. As a result, the MIPS 2022 published methodology provides for a maximum payment adjustment of 15.4%, 10% of which will only come into play if a practice scores above the exceptional performance threshold of 89/100pts. This represents a change from 2021 where the exceptional performance bonus was triggered by scoring 85+ pts. The actual maximum adjustment is announced once the economic considerations that mandate the budget neutral nature of the program have been determined post 2022 result submissions. In addition to the shifting exceptional performance target, the penalty threshold was increased to 75 pts from 60 pts in 2021. Any practice that falls below 75 will be subject to a negative adjustment penalty of up to -9%.

In preparing for MIPS 2023 it is important for practices to be aware of some significant changes in the proposed methodology.

• Estimated maximum payment adjustment 6.9% representing 100pt score.
• Elimination of Exceptional Performance Bonus
• Penalty threshold remains at 75 points
• No changes in Cost portion of score which remains at 30%.
• Measures without a benchmark earn 0 points even when data completeness (70%) and case minimums (20) are met
  • Small practice (</=15 clinicians) continue to earn 3 points
• • Does not apply to new measures that are in the first 2 performance years of the program) Measures with a benchmark earn from 1 – 10 points (3pt floor is removed)
• Multiple quality measure and improvement activity changes.

For fact sheets on proposed changes and comparison tables Click Here

The time to review and plan is now to position your radiology practice for the best possible outcome and avoid future penalties.