December 10, 2020 Subject: Stop 2021 Medicare Cuts to Portable X-ray Providers!
On December 1, 2020, the Centers for Medicare & Medicaid Services (CMS) issued its 2021 Medicare Physician Fee Schedule (PFS) final rule. The final rule included a 6 pecent reduction in payment to Portable X-ray (PXR) providers effective January 1, 2021.
The cuts are being implemented in order to maintain budget neutrality while increasing payment for office-based evaluation and management visit codes, also called E/M codes, that primary care and some specialty health professionals use to bill for their services.
These cuts could not come at a worse time. New cuts on top of losses and incurred costs due to the COVID pandemic are unsustainable and could result in reduced access to care as PXR providers are forced to cut back service to an already vulnerable population.
November 20, 2020 Update to Covid code to cover supplies expense 99072-CMS WILL NOT PAY FOR IT
The American Medical Association (AMA) published a new Current Procedural Terminology (CPT®) code on September 8 that accounts for extra provisions to ensure patient and provider safety during a public health emergency. CMS announced on October 27 it has assigned CPT 99072 procedure status “B.” The code is effective immediately: BUT NON REIMBURSEABLE BY CMS CPT 99072 - Additional supplies, materials, and clinical staff time over and above those usually included in an office visit or other non-facility service(s), when performed during a Public Health Emergency as defined by law, due to respiratory-transmitted infectious disease.
Some third-party payers have and will reimburse providers for this new CPT code, others won’t. Status "B" means:
1. There are no RVUs for this code;
November 19, 2020
2. CMS considers it to be bundled with whatever service was provided that day;
3. CMS’ contractors will not pay for this service;
4. Providers may not bill the beneficiary for this service; and
5. Issuing an Advanced Beneficiary Notice related to this service is not an option.
Advocacy/Legislative Update. The APDA executive committee has been working with our Lobby partners, Cornerstone Government Affairs. During a board meeting that included Laura Bozell and Chris Sarley from CGA on November 19, 2020 there was discussion outlining our 2021 legislative strategy. Board members expressed concern about the unrelenting cost of Covid 19 ppe and testing. Many stated that the pxr industry is expected to follow the same Covid 19 guidelines as nursing homes but yet are not given access to funds to compensate them for their cost - as nursing homes have been given. The board and CGA are looking to pursue additional funds that may be left from the 2020 Covid Relief funds before the end of the year.
As a tool to further advance our legislative actions, APDA has formed a Legislative/Advocacy Committee with Will Irwin as Chair and John Cooke as Co-Chair. As Will and John organize this committee, they will soon be reaching out to members only for participation.....so stay tuned.
On December 3, 2020 the board and CGA will begin a needs assessment project as they strategize in preperation for 2021. The first step will include geopolitical mapping plans for 2021 in which member input will be needed. As this takes shape, look for requests for information, via questionaires, emails, etc.
Novitas, R Code issues are still being worked on. The Executive committee and CGA continue to meet with industry partners as we wait for a response from Novitas.
The anticipated across the board Radiology fee cut for 2021 has been addressed by APDA through the comment period. There is wide support by other industry partners such as ACR and legislators (see November 13th news article in our news section) to stop these cuts - especially during the Covid 19 National Emergency.
Stay tuned for more updates by accessing APDA's website Advocacy tab and weekly newsletters.
Questions? Comments? APDA needs your support to push for our Industry. MEMBERS ONLY can work with our Legislative/Advocacy team as we shape the portable diagnostic landscape for all providers. Not a Member? Join Today and become part of the movement!
November 10, 2020
Details coming soon on the formation of an APDA Advocacy/Legislative team and a strategy meeting with CSG to discuss next steps for portable x-ray as relates to changes in U.S. legislative leaders and President.
September 1, 2020
Q. Any updates on R Code initiative?
A. APDA will hold a web go to meeting on Friday, 9/11, at 1 PM eastern standard time (EST) for MEMBERS ONLY. The purpose of the call is to bring you up-to-date on APDA’s progress on its regulatory and legislative goals and to ask your help in achieving them.
Sign-on letter: We are asking members of Congress to sign-on to a letter to CMS directing the agency to:
- Pause all R-Code reimbursement reviews until the end of the pandemic.
- Adjust all R-Code transportations rates to cover the added costs of Covid-19 for the duration of the pandemic.
- Revisit the process for computing the R-Code for the purpose of developing a transparent methodology which insures adequate reimbursement.
Legislation: Because CMS has told APDA that it doesn’t have the necessary authority, we will be seeking potential Senate & House sponsors for a bill to remove PXR from Consolidated Billing.Our consultants, Laura Bozell and Chris Sarley, from Cornerstone Government Affairs (CGA), will be guiding these initiatives in two stages: (1) virtual visits to a handful of primarily Senate offices and (2) advocacy emails from you to Congressional members in the House & Senate in those states where you have operations. Some of you, particularly those who were active in the Washington, DC visits in December 2019, will be invited to join the virtual visits. All of you will be asked to craft personalized emails from templates prepared by CGA requesting Congressional support for our “Asks.”
July 30, 2020
Q. I understand APDA has brought on a new lobby group, Cornerstone. What is CSG's plan for pxr representation and initiatives?
APDA URGES ANY PORTABLE X-RAY PROVIDER THAT IS NOT A MEMBER TO JOIN TODAY! IT IS VITAL THAT ALL INDUSTRY PARTNERS PARTICIPATE AND SUPPORT THE FUTURE OF PORTABLE DIAGNOSTICS!
A. Your APDA Board has been working tirelessly over the last few months to represent every member around the country. Cornerstone has quickly helped us understand possible “Champions” on the Hill that could help all of our current efforts. With help from Cornerstone, we are again asking CMS the following:
- Request that CMS pause any rate reviews until after the pandemic
- Work with APDA and PXR companies to develop a transparent and practical methodology for adequate reimbursement for portable diagnostics
- Asked that they consider, due to our updated cost data from all of you, an immediate increase of 20% to all transportation codes to help offset our cost of COVID-19. The Board, along with CGA is currently scheduling Congressional meetings and will be reaching out to you to take advantage of past communications with your Senators and House representatives. Although it is a difficult time, we believe PXR companies are being heard and that we are gaining champions from many different areas and parts of the country that are pushing for our industry.Please be looking for updates from APDA and CGA. If you have any concerns, questions or assistance, please reach out to any of the Executive Committee or Board directly.
Q. Is APDA working for members in other regions against such R code cuts?
May 25, 2020
A. Yes, APDA has made a push for fair evaluation of the Rcode reimbursement for ALL regions.
APDA is collaborating with the R-Code Standing Committee, consisting of APDA and other industry partners for the next phase of our lobbying initiatives with CMS and Congressional offices. In April, we spoke directly to the Office of CMS Administrator Seema Verma about our requests and believe we made a strong case for CMS to act. The next phase of our effort focuses on applying pressure to CMS to direct Novitas and the other MACs to implement our requests. We expect a response from CMS within the next 2 weeks, after which time we will evaluate the need to engage more members of Congress directly and through a grassroots effort by PXR providers. We will keep you informed about those initiatives and anticipate mid-June to be a critical time for this initiative.Be assured that your APDA Executive Committee is fighting to protect the interests of all PXR providers. Do not hesitate to contact us with questions.
May 13, 2020
Q. Are there any updates to the R code cuts?
A. APDA is working diligently to fight these cuts and any future cuts. These proposed cuts have led to the formation of the R-Code Standing Committee, consisting of APDA and other industry partners such as the National Association for the Support of Long-Term Care (NASL). That Committee meets weekly to formulate our industry’s regulatory and legislative strategy with respect to these rate cuts in the time of COVID-19. Your President, Will Irwin, and your President-Elect, Ryan Kingrey, participate in every single meeting. The collaboration has resulted in letters dated 3/31/2020 to Novitas and to CMS dated 04/22/2020. Our “Asks” of Novitas and CMS are somewhat different but can be summarized below:
- Pause any pending portable x-ray transportation rate reviews until after the COVID-19 emergency subsides
- Implement a 10% increase in the portable x-ray transportation rate for the duration of the COVID-19 outbreak
- Recognize the dramatic increase in demand for EKGs and echocardiograms for which there is no transportation fee paid
- Understand that without these measures PXR companies will have no choice but to reduce services hours, days, and distances traveled as they reduce staff.
- Recognize the PXR company technologists are front line health care workers, who at great risk, perform critical diagnostic tests on the residents of LTCFs aimed at preventing unnecessary and dangerous transfers to the Emergency Room and/or Hospital
- Recognize that PXR should not be part of consolidated billing and that PXR charges are a small part of MPFS allowed charges (<0.1%)
March 25, 2020
Q. Novitas has proposed a huge cut in the R code, what is APDA doing to help its members?
A. Please see letter from APDA President
Dear APDA Members and Industry Partners,
This APDA Action Alert contains two important updates:
(1) Novitas reassessment of portable x-ray (PXR) transportation rates in Jurisdictions JH and JL, and (2) an action alert for providers to engage with their elected representatives and state-based stakeholders to secure a 10% transportation fee increase in ALL states and a pause in any MAC rate reviews due to the COVID-19 pandemic.
APDA has prepared instructions to assist you with this grassroots effort and we are asking providers in ALL states to reach out to their Members of Congress.
R-Code Changes in Novitas Jurisdictions JH/JL
As you are aware, Novitas is currently reevaluating the transportation payment rates for PXR in the following states: Arkansas, Colorado, Louisiana, Mississippi, New Mexico, Oklahoma, Texas, Delaware, Maryland, New Jersey, Pennsylvania, and the District of Columbia.
APDA Leadership along with the Dumbarton Group, convened a conference call with Novitas principals last week. This update covers some initial thoughts about what transpired between the APDA team and Novitas decision-makers.
During our call, APDA firmly stated our position that Novitas should:
- Maintain current rates until such time as new adequate rates for each state can be developed
- Ensure Medicare beneficiaries maintain access to timely portable x-ray services
- Create determinate, predictable reimbursement for providers
- Reject a “flat rate” application and take into consideration real variances between the 11 states and District of Columbia
While this issue remains fluid and the final outcome is unclear at this time, APDA’s meeting with Novitas resulted in the following:
- Novitas was complimentary about APDA’s collection efforts and our ability to increase industry participation with submitting detailed data
- Novitas confirmed the March 31, 2020 data collection period was still intact
- Novitas requested APDA to secure additional PXR companies cost data to increase industry participation
- Novitas would continue to work with APDA and other stakeholders during the review process
- Novitas provided the following timeline they will likely follow:
- Data collection period will expire on March 31, 2020
- Novitas will take 30-60 days to review data it received from all industry providers
- After a comprehensive review, Novitas will release new rates for each of the 11 states and DC
- Once the new rates are announced, the effective date will most likely begin 6 weeks from the date of the announcement
- Novitas indicated a single “flat rate” across all 11 states and DC would NOT occur. Novitas acknowledged there are geographic and demographic differences that create unique costs for each state.
During the meeting, APDA also reviewed a joint ADPA/National Association for the Support of Long-Term Care (NASL) letter to CMS on COVID-19 where we call upon CMS to:
- Immediately provide a 10% increase to PXR transportation rates in all Medicare jurisdictions while heightened infection control procedures are in place, and
- Pause all current Medicare Administrative Contractors (MAC) action on the reevaluation of PXR transportation rates for no less than six months or until the COVID-19 outbreak subsides.
We anticipate meeting with CMS, along with our allied stakeholders, to press for action on both the R-code and a fee increase due to COVID-19.
Action Items for APDA Members
APDA is asking all members to remain engaged in grassroots efforts to promote the new phase of this initiative and we have prepared instructions to assist you. We are specifically asking members to:
- Contact your respective Members of Congress and ask them to reach out to CMS and promote:
- Providing a 10% increase to PXR transportation rates in all Medicare jurisdictions while heightened infection control procedures are in place
- Pausing all current Medicare Administrative Contractors (MAC) actions on the reevaluation of PXR transportation rates for no less than six months or until the COVID-19 outbreak subsides.
- Reach out to state stakeholders and ask if they will write CMS and promote our new requests as stated above.
APDA remains hopeful with resolute efforts of our members and industry partners we can receive a positive outcome and secure rates that are palatable to all 50 states. APDA will continue to update members on this fluid issue that has a tremendous impact to our industry.
Click here for INSTRUCTIONS
Click here for APDA/NASL LETTER
Exciting News! Great Win for APDA members and the Industry! On September 26, 2019, the Centers for Medicare & Medicaid Services (CMS) finalized a rule to modernize the Portable X-ray Conditions of Coverage (CoC). As a result of joint advocacy efforts by the American Portable Diagnostics Association(APDA) and the National Association for the Support of Long-term Care (NASL), with support from AMDA – the Society for Post-Acute and Long Term Care Medicine. UPDATE to changes 9/30/2019 The final rule updating the Portable X-ray Conditions of Coverage (CoC) was published in today's edition of the Federal Register (September 30, 2019). This means the changes become effective in 60 days – November 29, 2019. Here is a link to the final rule published in the Federal Register: https://www.govinfo.gov/content/pkg/FR-2019-09-30/pdf/2019-20736.pdf Read More »
Important Announcement Impacting Your Portable Imaging Supplier's National Provider Identifier (NPI) and Health Plan Enrollment
After two years of work the NAPXP has successfully redefined the National Provider Identifier (NPI) for “Portable X-ray Supplier” with the goal of obtaining reimbursement for ultrasound transport and simplifying validation. There is much work still to be done which APDA will vigorously undertake. Please read about this opportunity below.
If you previously selected “Portable X-ray Supplier” as the “area of specialization” associated with your portable x-ray or imaging operation's National Provider Identifier (NPI), then please note the following revision impacting your NPI record.
“Portable X-ray and/or Other Portable Diagnostic Imaging Supplier” has replaced “Portable X-ray Supplier” in the NPI record for your portable x-ray operation. This change could also impact your enrollment with health plans other than Medicare.The change is effective July 5, 2016. NAPXP initiated this revision in 2014 when it requested a change to the Health Care Provider Taxonomy—the national classification system that is used to describe the area of specialization for individual health care providers and health care entities in their NPI records, when enrolling with health plans, and in some electronic health care claim transactions with payers. The National Uniform Claim Committee (NUCC) maintains the Health Care Provider Taxonomy.
NAPXP advocated on behalf of the portable imaging industry for a new area of specialization in the Health Care Provider Taxonomy that reflects contemporary portable imaging suppliers and the full scope of services they provide.Definition of Portable X-ray and/or Other Portable Diagnostic Imaging Supplier: In the Health Care Provider Taxonomy (version 16.0) released on January 1, 2016, “Portable X-ray and/or Other Portable Diagnostic Imaging Supplier” is defined as:A supplier that provides one or more of the following portable services, including but not limited to, x-ray, electrocardiogram (EKG), long-term EKG (Holter Monitor), bone densitometry, sonography, and other imaging services in accordance with all state and federal requirements, under the general supervision of a qualified physician. All necessary resources are transported to the patient's location where the services are performed.
Source: Health Care Provider Taxonomy (version 16.0); page 190. See attached.
Note: “Portable X-ray Supplier” has been eliminated from the Health Care Provider Taxonomy and is replace by “Portable X-ray and/or Other Portable Diagnostic Imaging Supplier.” The 10-digit alphanumeric code, 335V00000X, previously associated with Portable X-ray Suppliers has been transferred to Portable X-ray and/or Other Portable Diagnostic Imaging Supplier. Therefore, there is no change in the code. Building on its success with obtaining a new taxonomy classification for the portable imaging industry, NAPXP launched the “Taxonomy Promotion Initiative” in January 2016 to advocate for changes to federal regulations and Medicare policies that advance the new taxonomy classification such as: Payment for the transportation of all portable diagnostic imaging equipment and technical personnel to a patient location and payment for the set-up of all portable diagnostic imaging equipment since payment for transportation and setup is now unjustifiably limited to only portable x-ray procedures. A single enrollment with health plans under the new taxonomy classification is possible.