How Providers Can Avoid 2016 Medicare Payment Adjustments
By - On January 1, 2016, payment adjustments will begin for those Medicare eligible professionals not participating in 2014's Medicare Electronic Health Records (EHR) Incentive Program, confirms the Centers for Medicare & Medicaid Services (CMS). Medicare eligible professionals can circumvent the 2016 payment adjustment by applying for a 2016 hardship exception by July 1.
General overview of payment adjustments
Congress authorized payment adjustments under the Medicare EHR Incentive Program. Such payment adjustments are applicable to Medicare eligible professionals, eligible hospitals, and critical access hospitals (CAHs) that are not meaningful users of Certified EHR Technology within the American Recovery and Reinvestment Act of 2009 (ARRA).
Cumulative program-to-date EHR incentive payments reached over $28 billion by the end of last year. Medicare and Medicaid eligible professionals have received almost $7 billion and over $3 billion, respectively, as RevCycleIntelligence.com previously reported. Additionally, eligible hospitals account for over $17 billion in EHR incentive payments.
Payment adjustments can be effectively thwarted if meaningful use is demonstrated within the Medicare EHR Incentive Program or the Medicaid EHR Incentive Program. Last October, Medicare hospitals began receiving payment adjustments. Over 28,000 eligible professionals experienced a 2 percent decrease in their 2015 Medicare payments for failing to meet standards associated with the Electronic Prescribing (eRx) Incentive Program and the Medicare EHR Incentive Program, as EHRIntelligence.com reported.
Hardship exceptions are valid for 1 payment year. New applications must be submitted hereafter for payments continuing after the initial payment year has passed. Filing a hardship exception requires exhibiting proof of a circumstance beyond your management ability or control and clearly outlining how this circumstance hindered your ability to harmonize with meaningful use requirements.
A summary of eligible and ineligible professionals
Some healthcare providers are automatically granted a hardship exception. CMS says it will use Medicare data on these providers to complete evaluations of such. The submission of a hardship application is not needed from the following four types of providers, confirms CMS:
- new eligible professionals and eligible hospitals within their first year of the profession
- hospital-based providers with over 90 percent of covered professional services in either a hospital’s inpatient or emergency department
- eligible professionals with 90 percent of claims including Place of Service 21, Place of Service 23, and certain observation services within Place of Service 22
- eligible professionals with up-to-date PECOS specialty 6 months prior to the initial day payment adjustments go into effect; CMS lists specialties as Anesthesiology, Pathology, Diagnostic Radiology, Nuclear Medicine, and Interventional Radiology
The only types of eligible professionals who can participate in the Medicare EHR Incentive Program are: doctors of medicine, osteopathy, optometry, dental surgery, dental medicine, chiropractic, and podiatry, confirms CMS.
Hardship exemptions and automatic exemptions from the 2016 payment adjustment will be granted if a primary area of practice includes one of the following specialty codes: anesthesiology, diagnostic radiology, interventional radiology, nuclear medicine, and pathology. New eligible professionals and hospital-based eligibility professionals are also exempt, according to CMS.
Additionally exempt from submitting a hardship exception application are those who successfully demonstrated meaningful use of Certified EHR Technology in 2014 for Medicare or Medicaid EHR Incentive Programs. Failure to demonstrate successful meaningful use in either programs means physician fee schedule amount decrease by 2 percent, says CMS.
A formerly implemented certified EHR flexibility rule from CMS allowed eligible professionals the option to use either a 2011 EHR edition or a 2014 EHR edition to demonstrate effective meaningful use. As this rule was not confirmed until September, confusion arose among physicians as to whether or not the rule would be formally implemented. Medicare cuts ensued for those healthcare professionals who failed to meet 2013 meaningful use requirements. It is hopeful history will not be repeated to ensure a smoothly executed revenue cycle for healthcare professionals across the Medicare and Medicaid spectrum.
