For additional information on the PC MPPR and digital radiography provisions, as well as H.R. 2029, in general, please do not hesitate to contact Josh Cooper, Rebecca Spangler, or Chris Sherin.
Reimbursement for X-rays taken with plain film would be reduced by 20 percent in 2017 and all subsequent years on a per-scan basis. Reimbursement for computed radiography would be reduced by 7 percent between 2018 and 2022, followed by a 10 percent reduction in 2023 and all subsequent years on a per-scan basis.
The ACR worked with Congressional leaders to minimize the computed radiography reimbursement reductions and extend the phase-in period.
In the Calendar Year (CY) 2017 MPFS Rule, the CMS established a new modifier (modifier “FX”) to be used on film X-ray claims. Beginning January 1, 2017, this modifier is required on claims for X-rays that are taken using film in the physician office setting. The modifier would be required on claims for the technical component of the X-ray service, including when the service is billed globally, since the PFS payment adjustment is made to the technical component regardless of whether it is billed globally or separately using the TC modifier. The modifier must be used to report the specific services that are subject to the payment reduction and its accurate use is subject to audit.
In the CY 2018 MPFS Rule, CMS finalized the development of a new “FY” modifier to be used on claims for X-rays taken using computed radiography technology in the physician office setting. Computed radiography technology is defined as cassette-based imaging that uses an imaging plate to create the image involved. Beginning on January 1, 2018, this ”FY” modifier is required on claims for the technical component of the computed radiography X-ray service, including when the service is billed globally because the PFS payment adjustment is made to the technical component regardless of whether it is billed globally or billed separately using the TC modifier. The modifier must be used to report the specific services that are subject to the payment reduction and its accurate use is subject to audit.
In the CY 2017 HOPPS Rule, CMS established modifier “FX” for X-rays taken using film in the outpatient setting. The modifier must be used to report the specific services that are subject to the payment reduction and its accurate use is subject to audit.
In the CY 2018 HOPPS rule, CMS finalized a new “FY” modifier to be reported on claims including codes that describe X-rays taken using computed radiography in the outpatient setting. The “FY” modifier must be used to report the specific services that are subject to the payment reduction and its accurate use is subject to audit. Finally, CMS notes that when payment for film X-ray or computed radiography services are packaged into those for another item or service under the OPPS, there is no payment attributable to X-ray or computed radiography. As a result, there would be no corresponding payment reduction to either service, so long as it’s packaged.