The Future Of Radiology Under Appropriate Use Criteria And E/M Changes

Melody W. Mulaik MSHS, FAHRA, CRA, RCC, RCC-IR, CPC, COC, and Revenue Cycle Coding Strategies. Looking ahead to the effects of the Appropriate Use Criteria and E/M changes on Radiology in 2021.

After an unprecedented legislative push from physician groups across healthcare, we entered 2021 with dramatically reduced cuts to E/M reimbursement (from a 10.2% to only 3.32% decrease) and more time bought for radiology to effectively prepare for the looming Appropriate Use Criteria implementation. While radiologists breathe a sigh of relief, RCCS looks to the future of CMS policy under the Appropriate Use Criteria. We also view several E/M changes as representing the start of fundamental shifts in how we document E/M services. The experts at Revenue Cycle Coding Strategies have identified unique issues and opportunities facing radiology during this transition.

Appropriate Use Criteria: Prepare or Wait for Another Delay?

Appropriate Use Criteria (AUC) legislation was initially passed in 2014, set for implementation in 2017, however, after lobbying and pushback by the industry, CMS has repeatedly delayed the start date. Four years later, radiologists are looking at 2022 as the new potential start date, albeit skeptically.

Prepare Now, Benefit Now!

Despite the potential delay, Mulaik strongly recommends getting ready for the transition now. After seeing many hospitals and radiologists produce success in implementing preparatory processes, she stated “There’s a clinical benefit to doing it” and “it’s not just a hoop to jump through.” Considering the positive impacts of providing the appropriate clinical data to ordering providers, as well as the major consequences of being unprepared when the AUC is implemented, there are sizable justifications to preliminary adjustments, rather than waiting out the storm and betting on another pushback.

E/M Changes Signal the “New Normal” for Interventional Radiologists

Meanwhile, with diagnostic radiologists preparing for 2022 and beyond, interventional radiology is adjusting to 2021’s major E/M changes. One of the major changes was providing physicians the choice between medical decision-making (MDM) and time-based reporting. These distinctions determine E/M documentation and arrive alongside new outpatient guidelines.

While this change requires some administrative adjustment by interventionalists, we see the long-term effects as strikingly positive. It has become easier to justify and document higher levels of service. Radiologists accomplish this via the decision-making required or by tracking the amount of time spent. Furthermore, Mulaik observes that “practices are already reevaluating the opportunity to bill for their outpatient services” thanks to the changes. Revenue Cycle Coding Strategies is prepared as a company to assist radiology providers in being successful.

For IR moving forward, this reevaluation and simplification of E/M coding is indicative of CMS’s attempt to shift to easier documentation requirements, fewer codes, and more accurate billing. Both the Appropriate Use Criteria and the role of MDM and time-based recording reflect a gradual, yet fundamental shift in the healthcare industry. One that drives providers and physicians towards less complex and more effective documentation.

How Revenue Cycle Coding Strategies Can Help

Want to learn more about how these changes affect your organization and how to effectively adjust your billing? RCCS provides learning materials and personalized services that help you identify and solve your organization’s coding, documentation, and compliance challenges. Check out the 2021 Radiology Navigator Suite for comprehensive, up-to-date guides for radiology, written by radiology coding, compliance, and documentation experts. In order to identify and enact the latest changes to E/M for radiology, pick up the 2021 Navigator® E/M Services for Radiology.

Trouble finding and keeping certified coders? Browse RCCS services and outsourcing options to see how consulting, training, and coding by industry experts can impact your organization. Connect with an RCCS expert today to learn more.


A collection of Navigator resource guides for Radiology. Billing and Coding, Diagnostic Radiology, ICD-10, and E/M options are available.

Text: Industry Leading Coding, Billing, and Compliance Resources for Radiology.

Order the 2021 Radiology Navigator Suite above which addresses coding for Diagnostic Radiology and Interventional Radiology, as well as compliance, evaluation and management, and documentation.