Radiology Benefit Managers and Other Game Changers in Medical Imaging - This program is an educational activity supported by
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Radiology Benefit Managers and Other Game Changers in Medical Imaging This program is an educational activity supported by:
Radiology Benefit Managers and Other Game Changers in Medical Imaging Barbara Ossias Reimbursement Revenue Solutions, LLC bossias@reimbursementrevenuesolutions.com
Program Information Format: Text Only No Audio Effective Date: October 14, 2020 Expiration Date: October 31, 2021 Format: Self Instructional - Slides Educational Credits: One (1.0) ARRT Category A CE Credit. Estimated Completion Time: 1 hour Accreditation This course meets all criteria and has been approved by the AHRA, The Association for Medical Imaging Management for One (1.0) ARRT Category A CE Credit. For information on applicability and acceptance of continuing education credit for this activity, please consult your professional licensing board or other credentialing organization. Method of Participation/Criteria for Success To receive CE credits for participating in this activity you must successfully complete the online post examination. Online examinations return an immediate grade report. Upon receiving a passing grade of 80% or higher click continue and complete the evaluation form. To view and print your Statement of Credit click the Print/View Certificate link displayed from within your User Record page.
Program Information 1. Course Objectives 2. Opening 3. Impact of Radiology Benefit Managers on Medical Imaging 4. How to Be Successful in a Challenging Environment 5. Other Game Changers in Medical Imaging
COURSE OBJECTIVES
Course Objectives By participating in this presentation, you will Gain an understanding of the impact of Radiology Benefit Managers (RBMs) on medical imaging Have an overview of how RBMs work Learn how to be successful in a challenging environment Be aware of the other game changers in medical imaging 6
OPENING
Opening In 1993, an associate wrote “Diagnostic imaging is one of the most capital-intensive specialties in medicine and as such, will be targeted for health care reform over the next decade. As costs associated with providing imaging services will continue to increase, so will pressure to limit the use of imaging services and reduce the reimbursement for work performed. And the spread of managed care and other cost-saving programs will lead to increased competition among providers of imaging services”. In 2020, we live with mechanisms put in place to control those costs 8
Opening These mechanisms limit access to care and at the end of the day, there is varied opinion on their success and impact on patient outcomes A December 2019 article in “Radiology Business” states An exhaustive comparison of diagnostic imaging use between Medicare patients and the commercially insured may cast doubts about the effectiveness of radiology benefit managers, two radiology experts assert In a comparison of utilization rates across several modalities in two insured populations (traditional Medicare and commercial) from 2003 to 2016, researchers learned that usage trends seemed to mostly mirror one another 9
Opening “The lack of substantial difference in imaging utilization between these populations (including CT, PET and MRI) otherwise expected to require preauthorization raises the question of effectiveness of radiology benefits management to control non-Medicare utilization,” wrote the authors, both MDs from Weill Cornell Medical College “This lack of effect on utilization trends further suggests that cost savings realized by payers through radiology benefits management are being achieved through alternate mechanisms, such as steerage to lower-cost providers and cost shifting” they added 10
IMPACT OF RBMS ON MEDICAL IMAGING
The Impact of RBMs on Medical Imaging For the past two decades, payers have segued from commercial fee-for-service to marketing almost exclusively managed plans Exclusive Provided Organizations (EPOs) Health Maintenance Organizations (HMOs) – the largest segment of commercially insured patients Preferred Provider Organizations (PPOs) While the corporate line is “managed lives are healthier lives” managed lives are less-costly lives 12
The Impact of RBMs on Medical Imaging In the move towards managed care as the norm, not the exception, medical imaging has been scrutinized as a cost center as opposed to a cost saver Payers have decided if they control access to imaging, they have a better control of cost Often without thought to how early diagnosis can save cost on treatment 13
The Impact of RBMs on Medical Imaging Commercial/managed care payers subject almost all advanced imaging to prior authorization employing the use of Radiology Benefit Managers (RBMs) such as eviCore RBM partners act as “gatekeeper” for all advanced imaging procedures – gatekeepers as ordering physicians must go through them to be able to order a procedure And they consider advanced imaging pretty much anything above a simple x-ray or ultrasound 14
The Impact of RBMs on Medical Imaging RBMs develop clinical guidelines that are the basis for approval and often these guidelines are highly restrictive RBM oversight often has the effect of deterring use of imaging by adding another layer of bureaucracy for ordering physicians to deal with Those making decisions at an RBM often have no background in medical imaging and work off the approved clinical criteria, with no leeway on interpretation 15
The Impact of RBMs on Medical Imaging The RBM clinical guidelines that are the basis for approval will supersede any historical medical coverage policy from a payer Many payers no longer even both developing a coverage policy, but rather simply go with the clinical criteria developed by their RBM partner 16
The Impact of RBMs on Medical Imaging And it is not just commercial/managed care payers that are requiring prior authorization Medicaid fee-for-service and managed Medicaid plans are requiring prior authorization § Fee-for-service programs usually perform prior authorizations internally while managed plans will use the parent commercial payer’s RBM partner 17
The Impact of RBMs on Medical Imaging Even Medicare Managed Care, AKA Medicare Advantage, plans are requiring prior author for almost all advanced imaging And it is important to not these Medicare Advantage plans do not cover exacting the same as CMS cover – most cover per their commercial policies which are often more restrictive than traditional Medicare 18
The Impact of RBMs on Medical Imaging RBMs are paid to say no and have been very successful at doing so to the point the largest names in the business now manage other areas of healthcare As example, eviCore manages: Cardiology services Post acute care Gastroenterology Radiation oncology Medical oncology Sleep disorders Musculoskeletal procedures & Specialty Drugs therapies 19
The Impact of RBMs on Medical Imaging And despite the mixed results on RBM management discussed in the opening, this extreme oversight is here to stay 20
IMPACT OF RBMS ON MEDICAL IMAGING – HOW PROVIDERS CAN BE SUCCESSFUL IN A CHALLENGING ENVIRONMENT
Impact of RBMS on Medical Imaging – How Providers can be Successful in a Challenging Environment Know the medical coverage policies of the major payers important to their practice Know the clinical criteria of the RBMs these major payers work with Payers and RBMs for the most part publish medical coverage policies and clinical criteria And remember, do not count on these two components of coverage matching! 22
Impact of RBMS on Medical Imaging – How Providers can be Successful in a Challenging Environment Most payers do not even bother establishing policies, or when they do, it will be only for a select number of imaging procedures An example of an established medical coverage policy is Anthem Blue Cross Blue Shield for Breast MRI: § https://www.anthem.com/dam/medpolicies/abcbs/active/policies/ mp_pw_a053263.html Most allow their RBM partner to develop clinical guidelines 23
Impact of RBMS on Medical Imaging – How Providers can be Successful in a Challenging Environment Most RBMs have done away with human interaction – clinical coverage guidelines and the PA process are all online As example, AIM Specialty Health is the RBM for Anthem and they publish imaging criteria by body area, not modality: https://aimspecialtyhealth.com/wp- content/uploads/2020/03/AIM_Guidelines_AbdomenPelvis_Imagin g.pdf 24
Impact of RBMS on Medical Imaging – How Providers can be Successful in a Challenging Environment Guidelines to successfully secure authorization Perform a benefit investigation for each patient prior to scheduling a scan Find out of prior authorization is required § If required, what is the process – online, calling RBM partner, etc. Never assume all coverage is the same with any payer § As example, while one Aetna plan may not require PA, but others will – they sell over 450 plans, with varied coverage and requirements 25
Impact of RBMS on Medical Imaging – How Providers can be Successful in a Challenging Environment When coverage is in doubt, have a patient sign an Advanced Beneficiary Notice (ABN) and enforce it where you can For situations where an office fails to secure required PA they cannot enforce, but if they learn a service is non- covered during the process, they can bill the patient 26
Impact of RBMS on Medical Imaging – How Providers can be Successful in a Challenging Environment Know your payers - make sure before offering any advanced imaging that those payers that are a large part of your payer mix will allow the services in the practice specialty Learn if any payer RBM partners require the practice to be credentialed by the RBM HealthHelp, the RBM for Humana, requires all providers be credentialed with them before they we approve any procedures – they will not even initiate an approval until this has been done 27
Impact of RBMS on Medical Imaging – How Providers can be Successful in a Challenging Environment Do not be afraid to appeal denied approvals – if it is a covered indication, providers have the right to appeal! Post-decision options for denials can vary, based on the reason for the denial, the payer, the member’s plan, or even the member's residing state Depending on these factors and the amount of time that has lapsed since the denial decision, providers may be able to have a decision reevaluated via a Peer-to-Peer Consultation, formal reconsideration, or appeal 28
Impact of RBMS on Medical Imaging – How Providers can be Successful in a Challenging Environment During each of these stages, providers will be able to provide additional clinical information verbally or in writing In some cases, the RBM might also suggest an alternative recommendation for a test their guidelines show as more appropriate for the patient's condition These post-decision options do not always offer the potential for overturn of a denial decision 29
Impact of RBMS on Medical Imaging – How Providers can be Successful in a Challenging Environment eviCore and other Radiology Benefit Managers have been so successful at saying no and saving their payer partners cash they have expanded their service offerings eviCore now manages § Sleep studies § Clinical lab § Post-acute care § Specialty Drugs § Medical & Radiation oncology § Even gastroenterology 30
OTHER GAME CHANGERS IN MEDICAL IMAGING
Other Game Changers in Medical Imaging Payers are utilizing several tools to control access to imaging: In-network vs. out-of-network Place-of-service restrictions UHC limits type of site that can offer certain services Some BCBS plans will not cover mobile services for certain modalities Multiple modality restrictions Horizon Blue Cross Blue Shield of New Jersey requires five or more advanced imaging modalities are offered in a site 32
Other Game Changers in Medical Imaging Payers are employing other tools to control access to imaging: Requiring attestations that no purchased services are used § Humana’s RBM partner, Health Help, requires all provider to sign an attestation that the perform all services and do not purchase any services including reads Limiting which specialties can offer imaging services § Despite sports clinics being logical providers of MRIs, some payer or their RBMs will not allow imaging by that specialty 33
Other Game Changers in Medical Imaging Payers tools to control access to imaging: Requiring accreditation Reducing reimbursement Clinical criteria guidelines And every one’s favorite . . . . . 34
Other Game Changers in Medical Imaging . . . Reducing payment on advanced imaging procedures Reimbursement to radiologists, according to a study published in the Journal of the American Medical Association in 2019, dropped by more than 19.5%, and reimbursement to cardiologists dropped nearly 45% between 2006 and 2015 Medical imaging use in the US has dropped significantly reduced access to the technology thanks to cuts in reimbursement 35
Other Game Changers in Medical Imaging CMS is also starting to manage advanced imaging The Protecting Access to Medicare Act (PAMA) of 2014, Section 218(b), established a new program to increase the rate of appropriate advanced diagnostic imaging services provided to Medicare beneficiaries. Examples of such advanced imaging services include: computed tomography (CT) positron emission tomography (PET) nuclear medicine magnetic resonance imaging (MRI) 36
Other Game Changers in Medical Imaging Per CMS, the program impacts all physicians and practitioners that order advanced diagnostic imaging services and physicians, practitioners and facilities that furnish advanced diagnostic imaging services in: Physician offices Hospital outpatient departments (including the ER) Ambulatory Surgical Center (ASC) Independent Diagnostic Testing Facility (IDTF) 37
Other Game Changers in Medical Imaging This does not apply to Critical Access Hospitals (CAHs) and PPS-exempt Cancer Centers There will also be one-off exemptions: If the ordering professional has a hardship exemption for any of the following reasons: § insufficient internet access § EHR or CDSM vendor issues § extreme and uncontrollable circumstances 38
Other Game Changers in Medical Imaging CMS has educational information on the program available on their website https://www.cms.gov/Medicare/Quality- Initiatives-Patient-855 368 2736Assessment- Instruments/Appropriate-Use-Criteria-Program 39
Other Game Changers in Medical Imaging Under this program, when a practitioner orders an advanced diagnostic imaging service for a Medicare beneficiary, they will be required to consult a qualified Clinical Decision Support Mechanism (CDSM) CDSMs are electronic portals through which appropriate use criteria (AUC) is accessed The CDSM provides a determination of whether the order adheres to AUC, or if the AUC consulted was not applicable (e.g., no AUC is available to address the patient’s clinical condition) 40
Other Game Changers in Medical Imaging Many CDSM vendors are the main Radiology Benefit Managers: AIM Specialty Health Provider Portal eviCore's Clinical Decision Support Mechanism HealthHelp's Clinical Decision Support Mechanism A complete lists of CDSM vendors that are CMS approved can be found on the program website https://www.cms.gov/Medicare/Quality-Initiatives-Patient- Assessment-Instruments/Appropriate-Use-Criteria- Program/CDSM 41
Other Game Changers in Medical Imaging This program was to be fully implemented on January 1st 2021, but in the current COVID-19 environment has been pushed back by one year to January 1st 2022 AUC consultations with qualified CDSMs are required to occur along with reporting of consultation information on the furnishing professional and furnishing facility claims for the advanced diagnostic imaging service Any claims that fail to append this information will not be paid 42
Other Game Changers in Medical Imaging 2020 was to be the Education and Operations Testing Period, which started January 1st, but now testing will run through 2021 During this testing period claims will not be denied for failing to include proper AUC consultation information Claims without full information will be denied for dates of service after January 1st 2022 43
RESOURCES
Resources Radiology Benefit Manager Clinical Criteria AIM Specialty Health: § https://aimspecialtyhealth.com/resources/clinical-guidelines/radiology/ eviCore: § https://www.evicore.com/solutions/health-plan/utilization- management/radiology National Imaging Associates: § https://www1.radmd.com/solutions.aspx 45
Resources Guerbet offers reimbursement support in partnership with Reimbursement Revenue Solutions, LLC Barbara Ossias § 603 324 7173 § bossias@reimbursementrevenuesolutions.com Toll free support Monday – Friday 9am to 5pm Eastern Time 855 368 2736 46
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