8-Part Series for Radiologists:
Protecting your Medicare Revenue Stream in 2017-2018
Part 8: Frequently Asked Questions and Additional Resources
We have provided some links to additional resources that may be helpful as you investigate QPP and PAMA for your radiology practice. These are followed by frequently asked questions (FAQs). The FAQs will be amended as readers pose additional questions about the two programs.
Resources for QPP
Resources for PAMA and Radiology AUC
Is MACRA going away? No, MACRA is a law passed by Congress. It went into effect on January 1, 2017. The QPP is the Medicare program that impacts provider fees for the next 8 years and beyond.
Isn't the QPP voluntary? Yes, QPP is voluntary. Which to Medicare, means, you can choose not to participate, but they can choose to cut your fees. You do not have to participate. However, if you are a qualifying provider for 2017, and you do not submit any 2017 data, you will have a 4% reduction of your 2019 fee schedule. In other words, it is a voluntary reduction of your fees if you qualify for QPP and choose to not submit data.
Isn't 2017 just a transition year for QPP? Yes, and you can elect to do "MIPS at your pace", which gives you four options for participation in 2017. However, if you do nothing in 2017, you may have difficulty ramping up your practice activities and reporting to submit a full year of data in 2018.
Aren't all radiologists exempt from QPP? While many are, there are multiple reasons why a radiologist may actually fall under the QPP. See Parts 2 and 3 for the details. It is best that you evaluate your specific situation and determine if you quality or not. Otherwise, you might not know until Medicare publishes your 2019 fee schedule, at which time you would have locked in two years of fee reductions for 2019-2020. That is because your 2019 fees were set by your 2017 participation and your 2020 fees by your 2018 participation (or rather lack of participation.).
Has PAMA been pushed back a year? The implementation date for the AUC for advanced diagnostic imaging is scheduled to go effect on January 1, 2018. In July 2017, Medicare proposed changing the implementation date to January 1, 2019 and dropping the penalties against radiologists. However, the comment period for the proposed changes ended on September 11, 2017. The final decision will be made in the fourth quarter of 2017.
Submit further questions to firstname.lastname@example.org and we will continue to update this list.
If you missed
Part 1: Introduction, CLICK HERE.
Part 2: Details of MACRA and the QPP. CLICK HERE.
Part 3: How to Participate with QPP if you are a Radiologist Who Qualifies. CLICK HERE.
Part 4: Overview of PAMA and the Appropriate Use Criteria (AUC) for Imaging. CLICK HERE.
Part 5: More on PAMA and the Appropriate Use Criteria for Advanced Diagnostic Imaging. CLICK HERE.
Part 6: Preparing for MACRA and QPP. CLICK HERE.
Part 7: The Financial Impact of Doing Nothing with QPP. CLICK HERE