CMS Clarifies CR to DR Policy (Modifier FY)
CMS recently released their quarterly update of the Hospital Outpatient Prospective System and clarified their policy regarding the applicability of modifier FY when images were performed using both CR and DR technology (multiple views). Modifier FY is to be reported when CR technology is the only technology used to perform the imaging service. If an imaging service has both CR and DR views, then the payment adjustment does not apply and modifier FY does not need to be used. AHRA urged CMS to provide clarification on these types of scenarios and we are pleased to see that they have clarified the policy. Here is the relevant language from the quarterly update (emphasis added):

CMS notes that section 1833(t)(16)(F)(ii) refers to an imaging service that is an X-ray taken using computed radiography technology. Where the imaging service is comprised of multiple images that include both X-rays taken using computed radiography technology and images taken using digital radiography, CMS does not believe the payment reduction would apply to that service. Instead, the payment adjustment applies to an imaging service that is an X-ray taken using computed radiography technology where the X-ray taken using computed radiography technology is not combined with digital radiography in the same imaging service.

This “CR to DR” policy was created by the Consolidated Appropriations Act of 2016 and it reduces Medicare reimbursement for X-rays taken using computed radiography technology by 7% until 2022 and 10% thereafter. The intent is to incentivize a transition to digital radiography technology and save Medicare money. The Consolidated Appropriations Act of 2016 also reduced Medicare reimbursement for film X-rays by 20%. If you perform an X-ray with film, you must use modifier FX.


Summary of CARES Act Supplemental Appropriations / Summary of CARES Act Healthcare Provisions
In the late hours of March 25, 2020, the Senate passed its $2 trillion “Phase III” response to the COVID-19 public health emergency (PHE), the CARES Act by a vote of 96-0.
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Summary of Employee/Individual/Business provisions in Coronavirus Aid, Relief, and Economic Security
The following are brief summaries of the major Employee/Individual/Business provisions included in the CARES Act. This summary does NOT include new GRANT programs established to assist certain industries during the COVID-19 pandemic. Summaries of those initiatives will be in a separate memo.
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COVID-19 Federal Response Update – Wednesday, March 25, 2020
Early this morning, Congressional and White House negotiators reached a deal to finalize its “Phase III” stimulus legislation. The final version of the bill is the product of over a week of negotiations between Republicans and Democrats in Congress and the White House. Congress has yet to release the official legislative text.
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COVID-19 Federal Response Update – Monday, March 23, 2020
Congress is still in negotiations on the Phase III stimulus bill. The Senate held procedural votes to advance the bill on Sunday and Monday. Both votes failed to advance the bill.
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COVID-19 Federal Response Update – Wednesday, March 18, 2020
President Trump and the White House Coronavirus Task Force held a press conference that announced more sweeping federal actions.
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Claims Processing Details Released for AUC Mandate – a Call to Action
Last month, the Centers for Medicare & Medicaid Services (CMS) released a Medicare Learning Network Article (MLN Matters) detailing certain claims processing aspects of the Appropriate Use Criteria (AUC) Mandate.
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Briefing on Surprise Billing Legislation
On Sunday afternoon, the House Energy and Commerce (E&C) Committee and the Senate Health, Education, Labor and Pensions (HELP) Committee announced they reached a bipartisan, bicameral agreement on legislation that addresses a number of healthcare issues. Most notably, the bill includes a long-sought agreement between the two Committees on how to design legislation that protects patients from unexpected out-of-network (OON) “surprise” medical bills as well as how the patient’s health plan should reimburse OON providers in surprise scenarios.
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Also see: section-by-section summary provided by committees
Federal Surprise Billing Legislation May Be Coming Soon
“Surprise” or out-of-network medical bills arise when a patient receives medical care at a hospital inside their insurance network but is later hit with an enormous bill because those providing the treatment were out-of-network. Patients are generally unaware and believe they are being covered, and these situations oftentimes cannot be avoided (e.g. emergency room services).
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