Frequently Asked Questions

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[EHR Incentive Programs]  What are the specific medical specialty codes associated with anesthesiology, radiology and pathology for the specialty-based determination for the granting of a hardship exception from the payment adjustments in the Medicare Electronic Health Record (EHR) Incentive Program?

The included Medicare Specialty Codes are diagnostic radiology (30), nuclear medicine (36), interventional radiology (94), anesthesiology (05), and pathology (22).

We note that current practice guidelines issued by the American College of Radiology for interventional radiology (94) indicate that both face-to-face patient contact (pre and post procedure) and follow-up care (longitudinal care) are expected as part of the scope of practice, and we may need to revisit this issue in future rulemaking.

Radiation oncology, together with surgical and medical oncology, is one of the 3 primary disciplines involved in cancer treatment according to the American College of Radiology practice guidelines. Radiation oncologists are therefore specialized oncologists as opposed to specialized radiologists and are not eligible for the specialty-based exception. If a radiation oncologist believes they meet the hardship exception criteria for lack of face-to-face patient interaction and lack of need for follow-up care they may apply for that exception, as can any eligible professional regardless of specialty.


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