Practice Management

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  • 1.  Fee Transparency Mandate Proposal Implications

    Posted 11-17-2019 14:12
    With CMS's release of their proposal mandating price transparency I am revisiting the Physician Payment file data CMS publishes each year.  The table below represents the weighted average radiology professional component (PC) charge for services performed in a "Facility" (i.e., hospital) by state by modality, expressed as a multiple of the Medicare Allowable for that state or region within the state.  This is a weighted average which takes into account the frequency with which a specific CPT is submitted.

    The table represents an overall picture of how each state's radiology charges compare to their Medicare allowed rate.  For example, professional component radiology charges in Wisconsin are 7.6 x their Medicare Allowable, followed by professional component charges in Illinois with a 5.1 x Medicare Allowable.  South Dakota radiology PC charges had the lowest multiple of 3.0.  The median PC multiple by state is 4.0 with 80% of the states charges havng a multiple of 4.51 or less.  I included a histogram of state charge multiples at the end of this post. 

    This is a view from the 10,000 foot level.  It gets very interesting when you drill down to the local level within each state. 

    Why is this important?  CMS recently issued a Proposed Rule requiring hospitals to publish their charges and negotiated rates. The rule requires hospitals to include charges, payment, and rates for physician services provided during an encounter for a specific subset of servicers about which consumers often inquire (see the table to the right). This means, if enacted, radiology groups will need to provide their charges and negotiated payment rates for this subset of procedures to the hospital so the hospital can provide an accurate charge/payment information to their patients.

    I recommend radiology groups begin analyzing how their charges compare to other groups in their area. Are your charges higher than your competitors? If so, by how much? Can you defend the higher fees to your hospital? To the public? Are you charges in line with others in your area? Are your charges less than your competitors?

    To give you an example of what I am writing about, I also analyzed one state's Screening Mammography charges using the Medicare Physician Payment file. (I could have chosen any state, but wanted a state that was large enough, but not too large, as well as a state I have no personal employment within.) I aggregated the Medicare payment data by address (e.g., group billing address to which the payments were assigned). For this analysis, I restricted the groups to those who collectively represent the top 80% of volume in the state. This is what I found:

    • The average Screening Mammography charge within the state was $92;
    • The group with the highest fee charged $134;
    • The group with the lowest fee charged $50; and,
    • Within one city, the fees ranged from a high of $133 and a low of $87 while another city's fees ranged from a high of $126 to a low of $54.


    I also performed a quick analysis of 3 other exams in this same cohort of groups for which CMS has mandated pricing transparency.  The table immediately above shows the lowest and highest charge for these 3 studies.  

    This same approach can be used to review any procedure, and even an entire fee schedule, and can performed for any state and/or any city or region within a state. Obviously, these are charges, and generally mean very little (except to the uninsured). Medicare and Commercial insurers generally pay their allowable amount. However, if this Proposed Rule is enacted, radiology groups need to be sensitive to the potential hospital and public relations issues if their charges are set unreasonably high vis-à-vis their competition. The point is that some of our facilities may not appreciate charges that our double our competition.  Those that understand where their fees fit in the competitive landscape will be better prepared to deal with this new mandate than those who don't.

    The Physician Payment Update File is an excellent resource for exploring how your fees compare within a state or region.  Having said that, the downloadable file is a 2+ Gb text file containing nearly 10,000,000 records - a massive text file. Suffice it to say it is difficult to use, and the programs most managers use in their daily work don't deal with well, if at all.  



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    Michael Bohl FRBMA
    Strategic Advisor
    Radiology Group, PC, SC
    Davenport IA
    (563) 421-5643
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  • 2.  RE: Fee Transparency Mandate Proposal Implications

    Posted 11-17-2019 14:18
    Thank you Michael. Your analysis and comments are right on. This is going to be a major change across-the-board in medicine.

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    Stanley Podolski CPA, CIA, CHBME
    President
    Fort Collins CO
    (970) 266-8795
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  • 3.  RE: Fee Transparency Mandate Proposal Implications

    Posted 11-17-2019 15:05
    Mike
    My understanding is that the hospital transparency rule is final; there is a proposed rule for payers. Please clarify if I am mistaken. Thanks





  • 4.  RE: Fee Transparency Mandate Proposal Implications

    Posted 11-17-2019 15:12

    Liz,

    Could be, I'm not up on all the details.  I understand the insurance side was sort of new. 

    Was the list of specific radiology codes a new twist? 

    MB

     






  • 5.  RE: Fee Transparency Mandate Proposal Implications

    Posted 11-18-2019 06:31

    Another proposed rule was released Friday (November 15th) and the final rule would require hospitals to make public all payer=specific negotiated charges and the amounts hospitals are will to accept in cash for 70 services, which includes 13 radiology procedures, effective Jan 1, 2021.   Here is a link to the Radiology Business article: https://www.radiologybusiness.com/topics/policy/cms-require-upfront-pricing-radiology-services?utm_source=newsletter&utm_medium=rb_news.

     

    Barbara F. Rubel MBA, FRBMA

    Senior VP, Marketing & Client Services

     

    brubel@msnllc.com

    904-657-2038 (Office) | 770-823-3597 (Cell)
    MSNLLC.com

     






  • 6.  RE: Fee Transparency Mandate Proposal Implications

    Posted 11-19-2019 16:08
    Upon rereading the rule, and after discussions with other RBMA and ACR chieftains, it appears that hospitals are likely only required to include employed physicians/providers' charges and negotiated rates along with their charges/rates, but are NOT required to include the charges of independently contracted radiologists who bill separately.  If so, that's good news.

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    Michael Bohl FRBMA
    Strategic Advisor
    Radiology Group, PC, SC
    Davenport IA
    (563) 484-0488
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