2022 Radiology Billing Changes

A number of forces are lined up to affect 2022 radiology billing, many of which are cuts. Here is what we know today:

  • Across the board 9.75% cut to the 2022 Medicare Physician Fee Schedule (MPFS) for all physicians
  • Proposed RVU changes for 2022 radiology billing in the 2022 MPFS[1]
    • The ACR says that if Congress does not intervene, the overall reduction for 2022 is approximately 2% for radiology, 9% for interventional radiology,2% for nuclear medicine, and 5% for radiation therapy and radiation oncology.
    • IR and radiation oncology are hit by planned wage increases for clinical labor staff
      • Due to budget neutrality rules, this means cuts in other places. In this case, IR and radiation oncology. Rates for some breast and prostate cancer treatments would be cut by 13%, while some advanced lung cancer treatment rates could drop by 22%.
      • A number of lawmakers have come out in opposition to this change.
      • A coalition has formed to fight the change. It includes the American College of Radiology, Society of Interventional Radiology, American College of Radiation Oncology and the United Specialists for Patient Access.
  • The imaging Appropriate Use Criteria Program penalty phase, that would have affected 2022 radiology billing has been delayed, again. It is now slated for January 2023. However, many experts are arguing for it to be incorporated into Medicare’s broader Quality Payment Program initiatives.
    • In a recent Health Affairs blog, quality experts with Johns Hopkins, Harvard and Weill Cornell advocated for folding the AUC program into similar endeavors.
  • Only minor Quality Payment Program/MIPS changes are expected for 2022 as CMS delays MVP (MIPS Value Pathways) initiatives originally targeted for 2022. MVPs would be incrementally added to the QPP upon availability. CMS has proposed seven MVPs that, if finalized, would become available beginning with the 2023 performance period
    • Rheumatology, stroke care and prevention, heart disease, chronic disease management, lower extremity joint repair (e.g., knee replacement), emergency medicine, and anesthesia.


[1]  In addition to RVU updates, estimates include the effects of redistributive effects of the CMS proposed clinical labor pricing update and phase-in implementation of the previously finalized updates to supply and equipment pricing