As reported in the Medicare Physician Fee Schedule and Hospital Outpatient Prospective Payment System Final Rule summaries posted on the ACR Web site, x-rays taken on film must begin using the FX modifier as of January 1, 2017. The Centers for Medicare and Medicaid Services (CMS) issued Change Request (CR) 9727, which reduces the technical component (TC) (including the TC portion of a global service) of X-ray imaging services provided using film.
The MPFS amount cannot be greater than the Outpatient Prospective Payment System (OPPS) amount. MACs will compare the OPPS Facility and Non-Facility Payment fields to the MPFS Facility and Non-Facility amounts and use the lower amount. The FX modifier will reduce whichever of these two amounts applies by 20 percent. The notice also states that the beneficiary is not liable for the FX modifier payment reduction.
The ACR requested that CMS publish the list of codes as soon as possible in order to help practices prepare and to ensure that their policy is applied to the correct codes. However, CMS responded that they did not publish an exhaustive list of applicable codes and intended to point to existing lists of physician fee schedule imaging services as they believe that physicians and non-physician practitioners are in the best position to determine whether a particular imaging service is an X-ray taken using film.
MLN Matters®Number: MM9727
MLN Matters®Number: MM9892
Related Change Request (CR) #: CR 9727