Regulatory Affairs Update

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Melody MulaikSheila-SferrellaBy Melody W. Mulaik, MSHS, CRA, FAHRA, RCC, CPC, CPC-H and Sheila M. Sferrella, CRA, FAHRA

The number of new guidelines and regulatory changes that are bombarding radiology has never been more voluminous than it is now. Staying on top of the key issues is challenging, but it is something that every imaging professional must do to be compliant and protect their organization.

At the 2016 AHRA Virtual Fall Conference we will present a fast-paced live session that provides an update on the information that you need to know to prepare for 2017 and beyond. We will review in detail how to ensure compliance with known policies, such the looming payment reductions associated with plain films and CR, as well as pending and proposed initiatives and how they will potentially impact operations.

The 2017 Final Rules for the Hospital Outpatient Prospective Payment System (OPPS) and the Medicare Physician Fee Schedule (MPFS) will not be finalized until the beginning of November, but this session will provide an easy-to-understand explanation of the key provisions that will impact imaging in 2017 and beyond.

This session will also include a detailed discussion regarding CMS’s site neutral payment policy. This policy, which requires that any new off campus (greater than 250 yards away) facilities and/or new clinical families introduced into existing facilities after November 5, 2015 be paid under the MPFS vs OPPS, is unduly burdensome for imaging services. Imaging services have seen considerable declines in reimbursement under the MPFS since 2004, and it would be insufficient for a hospital/health system to cover the costs of these services. Limiting the ability of existing off-site facilities to move and/or to expand their imaging services without financial penalty will potentially create a hardship for the patients and increase the likelihood that the patient may not obtain the necessary service. AHRA recommends that CMS exclude imaging clinical families from the listing and allow facilities to expand these services with no financial penalty.

Another big area of concern for hospitals is that CMS has proposed to reduce the number of imaging Ambulatory Payment Classifications (APCs) from 17 to 8. This will result in significant payment reductions for the most commonly performed outpatient US and MRI services. Our session will highlight the financial impact of the most commonly performed outpatient procedures by modality so that attendees can understand the potential impact to their organizations.

Finally, this session will discuss the implementation of Appropriate Use Criteria (AUC). The CMS Proposed Rule contained language that the requirement to consult AUC would be implemented no earlier than January 1, 2018. Additionally, there is verbiage that states that CMS will not finalize a list of clinical decision support mechanisms (CDSMs) until mid-2017, which would leave only 6 months for an organization to select, procedure, install, and implement the chosen CDSM.

Melody W. Mulaik, MSHS, CRA, FAHRA, RCC, CPC, CPC-H is president and co-founder of Coding Strategies, Inc. She may be contacted at 

Sheila M. Sferrella, CRA, FAHRA is senior vice president, Regents Health Resources, Franklin, TN. She can be contacted at


  1. I attend this session at the 2016 annual meeting. I learned so much! Don’t miss this event.

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