Industry News, March 2025

On March 15, 2025, the President signed into law the Full-Year Continuing Appropriations and Extensions Act of 2025 (H.R.1968) to maintain federal funding and extend temporary Medicare telehealth flexibilities through September 30, 2025, which is the end of the fiscal year (FY). However, this spending package excluded the so-called "doc fix" to reverse the 2.83 percent Medicare pay cut for physicians which was effective January 1, 2025.

Extension of Telehealth Flexibilities, Exclusion of "Doc Fix"

Exclusion of Doc Fix
This has been the fifth consecutive year of Medicare physician pay cuts in addition to the Centers for Medicare & Medicaid Services (CMS) estimation of a 3.5 percent rise in the Medicare Economic Index (MEI), which measures the inflation of physician practice costs.

Many medical groups have criticized this bill for not addressing the pay cut, including the Medical Group Management Association (MGMA), American Society for Radiation Oncology (ASTRO), the American College of Radiology (ACR), and the American Medical Association (AMA), among others. Yet, physician advocates and lobbying groups are still optimistic Congress will address this issue through the reconciliation bill later this year. 

In a press release, Congressman Greg Murphy, M.D. said, "... Congress cannot delay protecting Medicare beneficiaries' access to affordable, high-quality care any further. I appreciate Speaker Johnson's leadership and his commitment to addressing these harmful cuts through budget reconciliation."

Extension of Telehealth Flexibilities
The telehealth flexibilities initially introduced during the COVID-19 pandemic have been essential in expanding healthcare access for Medicare beneficiaries. This includes the removal of geographic restrictions; expansion of practitioners to offer telehealth services; coverage of audio-only consultations; allowance of Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) to provide telehealth services; and delay of certain in-person requirements for mental health services. 

While telehealth and medical groups applauded the telehealth flexibilities extension for another six months, they also noted another short-term extension creates uncertainty for providers and patients. They continue to advocate for more permanent solutions beyond the pandemic-era flexibilities.

In a statement by Telehealth Access for America (TAFA), spokesperson Julia Mirich said, "The uncertainty surrounding telehealth coverage over the last several months reiterates the need for a permanent telehealth solution that provides peace of mind for both patients and providers. Congress must prioritize permanent protections to put patients first and unlock the full potential of telehealth."

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ACR Opposes Federal Proposition Allowing Nonphysicians in the B Reader Certification Program

In response to a request for information (RFI) from the Centers for Disease Control's (CDC's) National Institute for Occupational Safety and Health (NIOSH), the American College of Radiology® (ACR®) expressed its disapproval of the proposed expansion of NIOSH B Reader Certification Eligibility to include nonphysician nurse practitioners (NPs) and physician assistants (PAs) to read x-rays under the B Reader certification.  

The NIOSH B Reader Program trains and certifies physicians in the International Labour Organization (ILO) International Classification of Radiographs of Pneumoconioses. In the U.S., B Readers classify chest X-rays of workers participating in health surveillance programs, specifically workers who are exposed to mineral dust (such as coal mine dust and asbestos) that can cause pneumoconiosis. These B Readers also perform classifications in other settings, including research, legal, and evaluation for compensation programs. This certification is not a license to practice medicine, so physicians must perform their responsibilities in accordance with the medical licensure laws of their states and territories. The ACR has a long history of collaboration with the NIOSH by helping to develop the certification training for B Readers.  

According to NIOSH, the B Reader program currently is based in 35 states and 2 territories. Its purpose for expansion would be to increase the number of B Readers by including NPs and PAs in the certification program.

The ACR stated its comments were informed by feedback from B Readers and nonphysician providers alike, and stated the evidence does not support the "assumed inability" of physicians to meet the current demands. Moreover, the ACR advised there may be reductions in quality, consistency and accuracy if certification requirements were revised to include nonphysician providers. 

The ACR suggested other improvements in the program, such as:

• Modernization of case distribution;
• Evaluation and upgrade of incentives and compensation;
• Revision of the self-study syllabus;
• Extension of certification from 5 years to 10 years; 
• Funding of AI tools for B Reader use;
• Promotion of B Reader certification; and
• Advancement of imaging quality assurance.

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ACR Announces Advancements in Lung Cancer Screening

On March 12, 2025, the American College of Radiology (ACR) announced the significant evolution and expansion of its current Lung Cancer Screening Registry (LCSR) into the Early Lung Cancer Detection Registry by the end of 2025. The intent of this expansion is to provide diagnostic performance feedback on the management of incidental pulmonary nodules (IPNs) that are identified during screenings, ensuring adherence to ACR recommendations and timely follow-ups. The initiative seeks to reduce the number of patients with IPNs who are lost to follow-up, which is estimated to be around 60 percent of patients by the ACR. Reducing this percentage will improve early detection and patient treatment outcomes. 

Concurrently, artificial intelligence (AI) is making notable strides in lung cancer screening. A recent study demonstrated that AI could accurately rule out negative low-dose CT (LDCT) scans, potentially reducing radiologists' workloads by up to 79 percent. The AI system achieved a negative predictive value of 99.8 percent, ensuring that all histologically confirmed cancers were flagged for further review. This integration of AI not only streamlines the screening process but also maintains high diagnostic confidence, addressing logistical and financial challenges associated with widespread LDCT screening implementation. 

For medical billing and coding professionals, these developments highlight the importance of staying updated with evolving screening protocols and AI applications. Accurate documentation and coding of AI-assisted screenings and follow-up procedures for IPNs are crucial for compliance and reimbursement. As AI becomes more integrated into diagnostic workflows, professionals should anticipate updates to coding guidelines that reflect these technological advancements. 

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ROCR Bill Reintroduced to Congress

In a significant move toward enhancing cancer care, bipartisan legislation known as the Radiation Oncology Case Rate (ROCR) Value-Based Payment Program Act of 2025 was reintroduced to Congress on March 14, 2025. Led by Senators Thom Tillis (R-NC) and Gary Peters (D-MI), along with Representatives Brian Fitzpatrick (R-PA), Jimmy Panetta (D-CA), John Joyce, MD (R-PA), and Paul Tonko (D-NY), the bill aims to modernize Medicare reimbursements for radiation therapy, ensuring patients receive high-quality, patient-centered treatment.  

The current Medicare payment system for radiation therapy operates on a per-treatment basis, which some argue incentivizes longer courses of treatment rather than focusing on patient outcomes. The ROCR Act proposes a shift to episode-based payments, aligning financial incentives with evidence-based care and prioritizing the quality and value of treatments over the quantity of sessions administered.  

"The ROCR Act modernizes Medicare's payment system to ensure cancer patients receive the best care possible," stated Senator Tillis. "Current reimbursement policies reward quantity over quality, making it harder for physicians to provide the tailored, high-quality care cancer patients deserve."  

A notable feature of the ROCR Act is the Health Equity and Achievement in Radiation Therapy (HEART) initiative, designed to address disparities in cancer treatment. This initiative aims to provide cancer centers with funds to support patients facing transportation challenges, which can hinder access to radiation treatments. The HEART initiative is based on a model from a National Cancer Institute-funded study that reduced disparities, improved treatment completion, and increased survival rates in a North Carolina community, with plans to expand this evidence-based policy nationwide. 

The bill has garnered support from over 80 organizations, including the American Society for Radiation Oncology (ASTRO) and the American College of Radiation Oncology (ACRO). These endorsements reflect a broad consensus on the need for payment reform in radiation oncology to ensure sustainable, high-quality care for patients. 

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60-Day Rule Policy Update

As of January 1, 2025, the Centers for Medicare and Medicaid Services (CMS) implemented the final rule policy to the Affordable Care Act's "60-day rule," significantly changing how healthcare providers must report and return Medicare and Medicaid overpayments.

The policy now allows for a temporary suspension of the 60-day deadline to report and return overpayments if a provider is conducting a timely, "good-faith investigation" into potential related overpayments. This investigation period is capped at 180 days and is essentially a "grace period" to allow time for review before returning funds. This policy update aims to provide more flexibility for healthcare providers to accurately identify and report overpayments while conducting thorough investigations. 

Additionally, the update drops the "reasonable diligence" guideline defining when a provider has identified an overpayment. According to the CMS 2025 Medicare Physician Fee Schedule Final Rule, identification occurs when a provider has actual knowledge of an overpayment or acts with "reckless disregard" or "deliberate ignorance" of a potential overpayment. This new guideline aligns with language used in the False Claims Act when an overpayment is identified. 

The Affordable Care Act (ACA), enacted in 2010, established the 60-day rule, which requires Medicare and Medicaid providers and suppliers, as well as Medicare Advantage and Medicare Part D Drug Plans to report and return overpayments within 60 days of identifying them. Non-compliance with this rule has significant consequences. 

Providers and organizations that fail to adhere to the 60-day deadline may face substantial fines under the Civil Monetary Penalties Law. Additionally, retaining an identified overpayment can now trigger liability under the False Claims Act, which may result in further penalties for each claim and potential treble (triple) damages. 

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CERT Additional Documentation Request Letter Schedule Update

The Centers for Medicare and Medicaid (CMS) established the Comprehensive Error Rate Testing (CERT)   program to "monitor and report the accuracy of Medicare fee-for-service (FFS) payments." The CERT contractor reviews a sample of processed claims. If a claim does not meet Medicare's coverage, coding, or billing policies, or a provider does not submit medical records for that claim when requested, the claim is counted as a total or partial improper payment error, subject to overpayment recovery by the Medicare Administrative Contractor (MAC). MACs evaluate CERT error rates to update their internal process and identify areas for Provider Outreach and Education.

In an announcement made by Palmetto GBA, one of the A/B MAC's, there has been a requirement update to the Additional Documentation Request (ADR) schedule. An ADR can be requested by a CERT review contractor to acquire medical records for each claim line sampled for CERT review. Beginning with Review Year (RY) 2026, providers will be counted as a non-response error and subject to overpayment recovery by MAC. 

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Reinforcing Hospital Price Transparency Compliance

On February 25, 2025, the White House issued an  Executive Order to reinforce healthcare price transparency compliance for radiology and other specialties. The order directs the Departments of the Treasury, Labor and Health and Human Services (HHS) to implement and enforce healthcare price transparency policy. Specifically:

• Confirm hospitals and payers disclose actual prices rather than estimates;
• Issue updated guidance or proposed regulatory guidance to safeguard pricing information is standardized and easily comparable across hospitals and health plans; and
• Update enforcement policies, and ensure hospitals and payers are compliant with the healthcare price transparency policy.

In November 2019, healthcare price transparency was mandated by the administration at that time, and the Centers for Medicare and Medicaid (CMS) finalized the policy, effective January 1, 2021. The White House noted progress has “stalled” over time, and the administration wants to re-start focus on the policy.  

In alignment with the Executive Order, CMS is planning a more organized monitoring and enforcement approach, and non-compliance will be met with prompt enforcement actions.

The current requirements of the hospital transparency policy are codified in regulations at 45 CFR Part 180 and apply to facilities that meet the definition of a hospital (defined at 45 CFR § 180.20) and that are not otherwise excepted (see 45 CFR § 180.30(b)). Each hospital meeting those definitions is expected to provide “clear, accessible” online pricing information in two ways to help consumers shop and compare prices across hospitals, as well as help estimate the cost of care before going to the hospital:

1. A comprehensive machine-readable file will all items and services; and
2. A display of shoppable services in a consumer-friendly format.

CMS has developed and maintained tools to support hospitals in meeting some of the requirements for hospital price transparency, including the online validator, command-line interface (CLI) validator, MRF naming wizard, TXT file generator, and data dictionary GitHub repository. For any hospital price transparency questions, email [email protected]. 

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Reprieve for Radiology Practices from Corporate Transparency Act

The Corporate Transparency Act (CTA) aims to identify potential shell companies that participate in illegal activities such as money laundering, human trafficking, or drugs. A shell company is a business entity that exists primarily on paper with little to no significant operations. While they are often used for legitimate purposes like holding assets, managing risks, or facilitating mergers, shell companies can also be misused for the illegal activities previously mentioned. In radiology, the CTA is relevant because many radiology practices operate as limited liability companies (LLCs) or professional corporations. The CTA is primarily applicable to privately held small and medium-sized companies (e.g. LLCs and corporations) doing business in the United States. The CTA requires these companies to share details about their ownership or face fines. After some delays in enforcement, the CTA established a reporting requirement deadline of March 21, 2025. In February, the American College of Radiology (ACR) sent an update to its members strongly recommending that “practices covered by the act consult with a qualified healthcare attorney in their jurisdiction.” 

Radiology practices have now received a temporary reprieve from the reporting obligations mandated by the Corporate Transparency Act (CTA). The U.S. Department of the Treasury recently announced it will not enforce penalties for non-compliance with the March 21 deadline associated with the CTA. The Treasury Department is anticipated to release new regulations clarifying which entities must disclose ownership information, potentially limiting reporting requirements to foreign-owned companies only. The Financial Crimes Enforcement Network (FinCEN) plans to extend deadlines and propose rule modifications to alleviate the burden on small businesses.  
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As a result of the Treasury Department announcement, on March 14, 2025, the American College of Radiology (ACR) informed its members about this delay in enforcement of the CTA. The ACR emphasized that while penalties are postponed, the law itself remains active. “Although the government decided to postpone enforcing the act, the underlying law remains in effect. Congress will have to repeal or modify it if the Treasury Department eventually concludes that the law is no longer necessary. ACR will continue to monitor developments related to the act and provide updates.” Radiology practices are advised to stay informed about these developments and consult with legal counsel to ensure compliance with any forthcoming regulations. Additionally, a bipartisan bill titled the "Protect Small Businesses from Excessive Paperwork Act" has been introduced in Congress. Since multiple surveys have found most organizations to be unaware of CTA obligations and compliance costs, this legislation aims to extend CTA filing deadlines to January 1, 2026, to allow the Treasury Department time to educate businesses about CTA requirements. The bill passed in the House on February 11 and is awaiting consideration in the U.S. Senate.

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