Zotec Partners Radiology Digest | January 15, 2021

January 19, 2021

Radiology Digest: News from the week of January 15, 2021.

For Radiology Practices, 4 Financial Lessons Learned From the COVID-19 Pandemic
By Marty Stempniak | January 14, 2021 | Included in Radiology Digest – January 15, 2021
The COVID-19 pandemic has brought widespread upheaval to the radiology profession, affecting everything from operations to finance, human resources and regulations. With that has come numerous lessons for the field to follow now and beyond the crisis.

That’s according to a new review from experts across five medical centers, published Monday in Academic Radiology. While the past year has been painful, they believe it has also helped position the best radiology groups to navigate future economic downturns, “even in the most trying circumstances,” such as today’s pandemic reality.

“While COVID has created major disruptions for our healthcare system and has had devastating financial and medical consequences for many of our patients, the pandemic has also created many opportunities to accelerate the ongoing evolution of radiology practices,” Jonathan Kruskal MD, PhD, with the Department of Radiology at Beth Israel Deaconess Medical Center, and co-authors wrote Jan. 13. “Taking these into consideration may allow practices—especially those within an academic medical center—to transform towards a stronger, more resilient and more cohesive framework,” they added later.

Kruskal et al. offered up more than a dozen lessons learned from the public health crisis. Here is a quick look at those that affect the financial side of the equation. You can read the entire review here.

  1. Undertake a financial risk assessment
  2. Manage your practice’s operating expenses
  3. Optimize your clinical income and revenue streams
  4. Optimize cash flow, access, liquidity and availability
    To read more, go to Radiology Business.

New Rule Makes It Harder for HHS to Penalize Guidance Violations
By Michael Brady | January 12, 2021 | Included in Radiology Digest – January 15, 2021
HHS officials bolstered President Donald Trump’s deregulation agenda on Tuesday, signing off on a rule that makes it more difficult for regulators to go after individuals and organizations for not following standards laid out in guidance documents.

The rule effectively bans the department from penalizing individuals and organizations for noncompliance with a standard or practice if HHS only announced it in a guidance document. It also lays out a substantial process HHS must follow to carry out civil enforcement actions for potential violations. HHS said the rule is necessary to ensure fairness.

“HHS can only apply standards or practices that have been publicly stated in a manner that would not cause unfair surprise,” according to a department statement.

In addition, HHS can only carry out civil administrative inspections if the department’s inspection process is publicly available.

“Whenever HHS relies on a document arising out of litigation to establish jurisdiction in future civil enforcement actions, HHS must publish that document and an explanation of the document’s jurisdictional implications,” the department said in a statement.

The rule also requires HHS to provide individuals and organizations with written notice of a guidance violation and a chance to respond before pursuing legal action.
“A cornerstone of fair governance is transparency—regulated parties need to know in advance the standards by which the government will judge their conduct,” HHS Chief of Staff Brian Harrison said in a statement.

The rule takes effect immediately.
To read more, go to Modern Healthcare.

ACR Concerned New Rule Would Set the Stage for ‘Highly Controversial New National Practice Standards’
By Marty Stempniak | January 12, 2021 | Included in Radiology Digest – January 15, 2021
The American College of Radiology is voicing concerns over a new federal regulation it believes is setting the stage for “highly controversial new national practice standards.”

ACR’s anxieties stem from an interim rule issued back in November, outlining Veterans Affairs providers’ scope of practice during the COVID-19 pandemic. That includes allowing VA clinicians to operate across state lines, regardless of local requirements, and asserting the massive health system’s ability to establish national practice standards across its 1,200-plus facilities.

In comments submitted Friday, ACR acknowledged this rule was merely meant to “confirm already-existing VA authorities.” However, the college is troubled by a potential slippery slope that could eventually lead the health system away from care teams guided by medical doctors.

“Undoubtedly the national practice standards envisioned by this rulemaking would undermine the integrity of physician-lead healthcare teams, resulting in a two-tiered system whereby veterans are denied the same level of high quality, physician-led healthcare that they could otherwise receive in the public sector,” Howard Fleishon, MD, chair of the college’s board of chancellors, wrote Jan. 8, ahead of the Monday deadline to submit comments. “ACR is concerned that allowing nonphysician providers to practice independently of a physician’s clinical oversight could seriously jeopardize the quality of care our veterans receive.”

Fleishon is additionally worried these standards could undermine states’ authority to oversee and regulate local care, and he and ACR are asking Secretary of Veterans Affairs Robert Wilkie to rescind the interim final rule.

“Veterans deserve high quality, physician-led, patient-centered care, and their access to such care should not be abrogated via this IFR and subregulatory guidance,” he concluded.

To read more, go to Radiology Business.

Indiana Taps Zotec for Statewide COVID-19 Vaccine Management System
Katie Adams | January 11, 2021 | Included in Radiology Digest – January 15, 2021
The Indiana Department of Health partnered with Zotec Partners to deploy a statewide COVID-19 vaccine information management system, the healthcare revenue cycle management company announced Jan. 11.

Zotec Partners’ platform alerts eligible vaccine recipients via text reminders, helps recipients schedule appointments for their first and second dose, tracks vaccine inventory status and determines which areas of the state are most in need of vaccines.

Hoosiers have already scheduled more than 460,000 COVID-19 vaccination appointments using the system, and the state plans to use the platform to schedule 300,000 more appointments by the end of January.

Zotec began working with Indiana’s health department in April by providing IT support for COVID-19 testing.
To read more, go to Becker’s Hospital Review.

CMS Recalculates Medicare Physician Fee Schedule Rates for 2021
By Jacqueline LaPointe | January 11, 2021 | Included in Radiology Digest – January 15, 2021
CMS has updated Medicare Physician Fee Schedule rates for 2021 after a COVID-19 stimulus package mitigated budget neutrality cuts finalized in a December rule.

The Consolidated Appropriations Act, 2021 passed by Congress on Dec. 21, 2020, enacted a 3.75 percent increase in Physician Fee Schedule payments for all providers in 2021 to “support physicians and other professionals in adjusting to changes in payment for physicians’ services during 2021.”

The $1.4 trillion COVID-19 stimulus package also suspended payments for Healthcare Common Procedure Coding System (HCPCS) code G2211 for three years, which also impacted the budget neutrality requirement for the Physician Fee Schedule.

G2211, an add-on code for the complexity inherent to evaluation and management (E/M) visits, accounted for about $3 billion, or three percent, of spending in the Medicare Physician Fee Schedule, according to the American Medical Association (AMA).

The delay in implementing the code will reduce the budget-neutrality adjustment, and as a result, some specialists will no longer face significant rate cuts as laid out in the 2021 Medicare Physician Fee Schedule final rule, the Association said.

The rule finalized cuts of up to 10.2 percent for certain specialties and services because of a budget neutrality requirement that forces any significant increases in Physician Fee Schedule payments to be offset in other areas.

CMS had decided in the final rule to boost rates for E/M services that support primary care and chronic disease management, which triggered the budget-neutrality adjustment factor for 2021.

The agency reported that the final rule decreased the Physician Fee Schedule conversion factor by $3.68 to $32.41 to reflect a statutory update of 0.00 percent and the adjustment to account for changes in relative value units and expenditures that would result from finalized policies.

“This finalized policy marks the most significant updates to E/M codes in 30 years, reducing burden on doctors imposed by the coding system and rewarding time spent evaluating and managing their patients’ care,” CMS Administrator Verma said at the time. “In the past, the system has rewarded interventions and procedures over time spent with patients – time taken preventing disease and managing chronic illnesses.”

Specialty providers have opposed the rate cuts, which would have disproportionately impacted certain specialties and services during the COVID-19 pandemic.
To read more, go to Revcycle Intelligence.

HHS Extends COVID-19 Public Health Emergency Through Spring
By Rachel Cohrs | January 8, 2021 | Included in Radiology Digest – January 15, 2021
HHS on Thursday extended its COVID-19 public health emergency declaration, which is attached to increased funding for healthcare providers and regulatory flexibilities.

The declaration was set to expire on Jan. 20, the day when President-elect Biden is scheduled to be inaugurated. The renewal takes effect on Jan. 21 and extends for 90 days. The renewal eliminates the risk of a lapse as the new administration takes over.

“Our work to combat the virus will continue, as will our work to ensure a peaceful and orderly transition,” HHS Secretary Alex Azar said in a tweet announcing the renewal.

Significant anxiety swirled around whether the Trump administration would renew the declaration in summer 2020, but public health experts expect the Biden administration to be more aggressive with the federal COVID-19 response and more likely to continue renewing the designation.

Some notable policies tied to the public health emergency are the Medicare inpatient 20% add-on payment for COVID-19 patients, increased federal Medicaid matching rates and maintenance of effort requirements, requirements that insurers cover COVID-19 testing without cost-sharing and waivers of telehealth restrictions.

Adjustments CMS made to the Medicare Shared Savings Program for accountable care organizations are also connected to the length of the public health emergency. The number of months the emergency lasts affects the amount of shared losses an ACO must pay back to CMS.

Congress also conditioned increased Medicaid funds on states covering vaccines without cost-sharing for enrollees, but that requirement expires with the public health emergency.
To read more, go to Modern Healthcare.

Hospitals Slow to Disclose Their Payer-negotiated Rates
By Michael Brady | January 8, 2021 | Included in Radiology Digest – January 15, 2021
Many hospitals are breaking new federal rules that seek to make public the prices they negotiate with insurers. But even among those hospitals that post their payer-negotiated rates, such information is often difficult to find, unclear and nearly impossible for the vast majority of consumers to understand or use effectively, experts said.

The regulation took effect on Jan. 1 and mandates hospitals publish a machine-readable file online containing their payer-negotiated rates. It also requires them to make available a consumer-friendly display of at least 300 shoppable services, including 70 specified by CMS. Hospitals don’t need to post a list of shoppable services if they allow consumers to use a price estimator tool to calculate their out-of-pocket costs for all shoppable services.

The Trump administration originally unveiled the plan in June 2019, saying it would improve consumer choice, increase provider competition and lower healthcare costs. Hospitals rebuffed those claims, arguing it would allow insurers to conspire with each other to fix prices.

There’s mixed evidence about whether price transparency initiatives lower healthcare spending significantly, making the long-term impact of the new rules uncertain.

Hospitals successfully beat back CMS’ effort to roll out the new rule last January, delaying it for a year while they sued to block it. A federal appeals court in late December rejected the hospital industry’s arguments, though, and the new rule took hold.

The American Hospital Association has said it is weighing its legal options, which could include asking the full D.C. Circuit to review the ruling or appealing to the Supreme Court.

“The most significant thing is the judges actually came down on the side of wanting consumers to be well-informed rather than ill-informed,” said Cynthia Fisher, founder and chair of Patient Rights Advocate, a nonpartisan group that advocates for price transparency in healthcare.
To read more, go to Modern Healthcare.

Here’s What Radiologists Gained—or Avoided—After Trump Signed the Year-end Spending Bill
By Matt O’Connor | January 4, 2021 | Included in Radiology Digest – January 15, 2021
In case you missed it over the holiday season, President Donald Trump signed the $2.3 trillion year-end spending bill into law, ensuring radiologists and other physicians avoid significant
Medicare payment cuts. He had previously criticized the legislation and threatened to veto it altogether if lawmakers didn’t make certain changes unrelated to healthcare policy.

The official passage of the 2021 Consolidated Appropriates Act came on Dec. 27, providing stimulus payments to individuals and businesses battling the COVID-19 pandemic. Of interest to radiologists is the $3 billion injection to the Medicare Physician Fee Schedule mitigating reimbursement losses due to evaluation and management (E/M) coding changes that would have gone into effect last Friday.

Under the new bill, rad cuts will drop to about 4%, compared to the 10% outlined in the finalized MPFS proposal first released last month. The American College of Radiology, part of a 74-member coalition, had for months been lobbying Congress to eliminate these reductions.

Along with the changes to E/M coding, the bill also postpones the go-live date for a controversial Radiation Oncology Advanced Payment Model to January 2022.

The spending bill also set into motion changes to surprise medical billing practices, removing the monetary threshold required to enter independent dispute resolutions, along with other adjustments.

Key mammography protections were also retained in the new legislation, maintaining the United States Preventative Services Task Force 2002 guidelines recommending screening every one or two years beginning at age 40. The omnibus spending bill extends the moratorium on controversial USPSTF recommendations for biennial screening at age 50 back until Dec. 31, 2022.

Finally, Congress on Sunday voted to push through a $741 billion defense bill previously vetoed by President Trump. The 2021 National Defense Authorization Act (NDAA) mandates Tricare beneficiaries receive permanent coverage for digital breast tomosynthesis, protections the Medical Imaging & Technology Alliance has long called for.
To read more, go to Health Imaging.

Learn more about what Zotec Partners can do for your radiology practice here.