Guidelines set admins scrambling

A Centers for Medicare and Medicaid Services proposal meant to streamline billing and other imaging management duties could actually backfire and create administrative havoc, according to radiology administrators.

The decision detailed in CMS's Transmittal 1823, issued Oct. 2, requires physicians and hospital administrators to disclose separately the place and date of service using new codes for the professional and technical components of imaging exams.

Medicare says the codes should reflect the actual place where each service was provided. Hospitals customarily bill based on where the examination occurred, not where the interpretation took place. Because the events usually take place at different locations and times, the new rules will mostly affect providers of imaging services by increasing paperwork and overhead costs, said Michael R. Mabry, executive director of the Radiology Business Management Association.

“It is really hard to figure out what the reimbursement impact would be from these changes,” Mabry said. “But we do know that it is going to change the way we practice and store information.”

Language in the transmittal suggests CMS harbored concerns that many physicians were misusing current place code 11. CMS tried to address this issue, but-largely by accident rather than design-it has issued guidelines that run counter to the way practices currently operate, Mabry said.

“In an attempt to help, CMS has potentially made the situation worse,” he said.

Responding to a request from the RBMA, the American College of Radiology, the Association for Medical Imaging Management, the Healthcare Billing and Management Association, and the Medical Group Management Association to delay implementation, CMS in December rescinded Transmittal 1823, replacing it with Transmittal 1873. The new document enforces the place of service requirement as of Jan. 4, but delays implementation of the date of service requirement until July.

The group had acknowledged the agency's move was well-intentioned, but worried the proposed reporting rules could confuse providers and lead to unforeseen adverse consequences.

“There is major confusion over the place of service transmittal. So far, Medicare administrative contractors are reported anecdotally to be telling radiologists not to change their billing practices,” said Thomas Greeson, a healthcare attorney with the law firm of Reed Smith in Falls Church, VA. “RBMA has crafted a questionnaire to aid business managers seeking guidance from Medicare carriers on how to respond to the transmittal.”