Posts Tagged MACRA

CMS Cancels Some Bundled Payment Proposals

Posted by on
CMS Cancels Some Bundled Payment Proposals

CMS released a proposed rule that reduced the number of mandatory geographic areas for the joint bundled payment program and cancels the cardiac bundled payment program model.

In response to the cut, the American College of Cardiology released a statement indicating the ACC “will continue to work with CMS on opportunities for clinicians to participate meaningfully in Advanced Alternative Payment Models. As we move from volume-based care to value-based care, the path forward is challenging and we must work together to find solutions.”

The cardiac bundled program was set to begin in January 2018, but the bundled payment programs have been delayed multiple times. By eliminating the bundling programs, CMS also removes one of the ways providers can qualify for MACRA’s 5 percent advanced payment model bonus.

“Changing the scope of these models allows CMS to test and evaluate improvements in care processes that will improve quality, reduce costs, and ease burdens on hospitals,” said CMS Administrator Seema Verma. “Stakeholders have asked for more input on the design of these models. These changes make this possible and give CMS maximum flexibility to test other episode-based models that will bring about innovation and provide better care for Medicare beneficiaries.”

Moving forward, CMS expects to increase opportunities for providers to participate in voluntary initiatives rather than large mandatory episode payment model efforts, including additional voluntary episode-based payment models, the agency said.

The episode payment models and the cardiac rehab incentive models were designed as mandatory payment models to test the effects of bundling cardiac and orthopedic care beginning in 2018.

Read the proposed rule here

Pin It

Tags: , , ,

Posted in: CMS

Leave a Comment (0) →

Physicians Can Now Apply for Hardship Exception for QPP

Posted by on
Physicians Can Now Apply for Hardship Exception for QPP

Physicians who have insufficient internet connectivity, “extreme and uncontrollable” circumstances or lack of control over the availability of certified electronic health record technology can begin applying for a hardship exception from the Quality Payment Program (QPP) requirement. The exception is for physicians eligible to participate in the Merit-based Incentive Payment System (MIPS). Hospital-based physicians are considered

Hospital-based physicians are considered special status and do not need to apply for a 2017 hardship exception.

 

Return to Pick-Your-Pace home page

Pin It

Tags: , , , ,

Posted in: MACRA

Leave a Comment (0) →

Free AQAF Assistance: Transition to MACRA’s Quality Payment Program

Posted by on
Free AQAF Assistance: Transition to MACRA’s Quality Payment Program

The Alabama Quality Assurance Foundation (AQAF), located in Birmingham, is a nonprofit consulting firm providing quality improvement assistance to the health care provider market through contract arrangements. Part of AQAF’s contract with CMS is to provide training to clinicians on the Medicare Access and CHIP Reauthorization Act (MACRA), the Merit-based Incentive Payment System (MIPS) or an Alternative Payment Model (APM). The training includes the four categories of the Quality Payment Program (QPP): quality, cost, advancing care information and clinical practice improvement activities, and the goal is to help all Alabama clinicians achieve a positive or neutral Medicare Part B Fee Schedule payment adjustment.

AQAF assists clinicians in understanding the four categories of the QPP: quality, cost, advancing care information, and clinical practice improvement activities. The goal is to help every practice choose its pace to participate so that all Alabama clinicians achieve a positive or neutral Medicare Part B Fee Schedule payment adjustment.

Technical assistance from the staff at AQAF is always FREE and available immediately by emailing TechAssist@Qsource.org, or calling toll-free Monday through Friday at 1-844-205-5540 from 8:30 a.m. to 5 p.m. CT.

For more information about QPP and to check your eligibility, visit https://qpp.cms.gov/.

 

Return to Pick-Your-Pace home page

Pin It

Tags: , , , , , , , ,

Posted in: MACRA

Leave a Comment (0) →

New Video Shows Physicians How to Avoid Medicare Payment Penalties

Posted by on
New Video Shows Physicians How to Avoid Medicare Payment Penalties

The Quality Payment Program (QPP) is the new physician payment system created by MACRA and is administered by the Centers for Medicare and Medicaid Services (CMS). Because the QPP is new this year, the Medical Association of the State of Alabama and the AMA want to make sure physicians know what they have to do to participate and the QPP’s “Pick-Your-Pace” options for reporting. This is especially important for those physicians who have not participated in past Medicare reporting and programs and may be less knowledgeable about the steps they can take to avoid being penalized under the QPP.

The AMA and the Federation stressed to CMS the importance of establishing a transition period to QPP and, as a result, physicians only need to report on at least one quality measure for one patient during 2017 in order to avoid a payment penalty in 2019 under the Merit-based Incentive Payment System (MIPS).

A new short video developed by the AMA, “One patient, one measure, no penalty: How to avoid a Medicare payment penalty with basic reporting,” offers step-by-step instructions on how to report so physicians can avoid a negative 4 percent payment adjustment in 2019. On this website, ama-assn.org/qpp-reporting, there are also links to CMS’ quality measurement tools and an example of what a completed 1500 billing form looks like.

 

Return to Pick-Your-Pace home page

Pin It

Tags: , , , , , , ,

Posted in: MACRA

Leave a Comment (0) →

Taking CDI Into the Physician Office Setting

Posted by on
Taking CDI Into the Physician Office Setting

 

CDI, or Clinical Documentation Improvement, is as familiar to physicians who practice in the hospital as other acronyms such as ICU, OR, ED – but in the physician office, CDI is relatively unknown. However, with the implementation of the Merit-Based Incentive Payment System, or MIPS, CDI in the physician office will become imperative.

Most physicians will fall under the MIPS provisions of MACRA, the Medicare Access and CHIP Reauthorization Act. CMS estimates that of the 1.3 million providers under MACRA, 1.2 million will be under the MIPS program. The Quality component of MIPS is familiar to most physicians, as it is similar to the previous Physician Quality Reporting System. One new aspect of MIPS, however, is the Resource Use or Cost. This component will be 10 percent of the physician’s MIPS score in 2018, increasing to 30 percent in 2019 and beyond. The Cost score will be derived from claims data and will be based on the CPT and ICD-10-CM codes billed. Correct and specific ICD-10-CM coding will be key to physician reimbursement in this model. Medicare, and other payers implementing similar reimbursement strategies expect that a patient with a certain diagnosis will incur an estimated cost. If the cost to treat the patient far exceeds the estimate, then the physician’s Resource Use/Cost score will be low – he/she will be considered to be an inefficient physician.

A specific example to illustrate this:  The physician treats a patient with diabetes. The only code he bills for this patient is E11.9 – Type 2 diabetes mellitus without complications.  However, this patient has diabetic retinopathy, diabetic neuropathy, and diabetic chronic kidney disease. The payer’s estimated annual cost for a patient with diabetes with no complications is $1,400, but this patient incurs much higher costs due to his complications.  The physician, therefore, appears to be inefficient, and his Resource Use/Cost score will suffer. The payer’s estimated cost for a patient with diabetic chronic kidney disease is $4,300. Had the physician coded as specifically as he could have, E11.319 for diabetic retinopathy, E11.40 for diabetic neuropathy, and E11.22 for diabetic chronic kidney disease, the higher cost would have been expected, and the physician would not be penalized for the care he is rendering.

One hindrance to CDI in the physician office setting is the use of electronic medical records and the implementation of “charge passing”, codes transmitting directly from the EMR into the practice billing system. Physicians may not choose the most specific, or even the most accurate, diagnosis code, but once those codes are passed onto the claim and filed to Medicare, there is no changing or correcting that information. Corrected claims will not be accepted for this purpose. Some practices use coders to review these claims before they are actually filed.  This usually does not involve 100 percent review of the documentation, but it would allow some coding errors to be caught. For example, if a coder noted the following diagnoses on the claim:  E11.9, N18.5, G62.9, he would be prompted to discuss with the physician that N18.5 – chronic kidney disease, stage 5, and G62.9 – neuropathy, are considered to be diabetic complications and should be coded as such. And if a coder is familiar with coding guidelines, understanding that certain diagnoses require additional codes, then when she notes G30.9 – Alzheimer’s disease on the claim, she can query the physician as to which additional code is appropriate, F02.80 – dementia in underlying disease without behavioral disturbance or F02.81 – dementia in underlying disease with behavioral disturbance.

This may require additional diagnosis coding training for physician office coders, and it will almost certainly require a change in mindset. Physician coders have focused on what is documented with the mantra “Not documented, not done.” But CDI requires a similar focus on seeing what is not documented, what should be there, what is likely true for that patient – and then querying the physician.

Electronic medical records have also contributed to some of the errors seen in that physician may not have been trained properly in diagnosis documentation and coding before having access to what is essentially the entire ICD-10-CM book in their EMR. The ICD-10-CM descriptions may not match the language the physician uses, although the code is correct. For example, in ICD-9-CM, the code for depression, unspecified was 311, and the description was Depressive disorder, not elsewhere classified. In ICD-10-CM, the code for depression, unspecified is F32.9, and the description is Major depressive disorder, single episode, unspecified. Physicians may not be able to identify the appropriate code without further diagnosis education. EMR vendors and office staff may try to set up shortcuts to assist the physicians in choosing the appropriate diagnosis code and create further issues. Two recent errors I have seen in my own auditing practice:  1.) physicians coding Crohn’s disease with small bowel obstruction when they intended to code for small bowel obstruction, unspecified and 2.) physicians coding psychophysiologic insomnia when they intended to code chronic insomnia. CDI in the physician office setting must include a detailed review of the ICD-10-CM code descriptions in the EMR.

CDI in the physician office setting does not have to be as formal a process as that seen in the hospital – it can be informal discussions with the physicians. It can be accomplished through real-time shadowing or end-of-day review, but it must occur before the claim is filed. A simple CDI process could look something like this:

  • Coder reviews record for correct coding based on physician documentation.
  • Coder talks with nurse and physician about code choices.
  • Coder identifies incorrect codes chosen – discovers confusing language in ICD-10 description.
  • Coder reviews with physician and makes changes in code descriptions to assist physician in most specific and correct coding.

The keys for coders will be continuing education, which may be in the form of informal chats with the physicians and clinical staff, review of ICD-10-CM guidelines and Coding Clinic guidance, review of medical policies which can be used to help guide physicians in documenting. And perhaps most importantly, respect for the physician’s priorities. The physician’s foremost interest is care of the patient, and CDI is simply helping the physician to understand that how he documents matters and providing the assistance he needs to make it so.

References

Medicare Quality Payment Program

Kim the Coder (also known as Kim Huey, MJ, CCS-P, PCS, CHC, CPC, CPCO, COC) works with clients to improve coding and documentation of services and to ensure compliance with Medicare and insurance company regulations. Ms. Huey is available for on-site visits for auditing and education as well as for on-the-record audits and general coding and reimbursement questions.

 

Pin It

Tags: , , , , ,

Posted in: MACRA

Leave a Comment (0) →

Meaningful Use and the Costs of Noncompliance

Posted by on
Meaningful Use and the Costs of Noncompliance

It is something of an understatement to note that the U.S. health care legal landscape is currently experiencing a degree of transition and uncertainty. There is no shortage of changes to discuss, debate, and, perhaps, grow apprehensive about. One development that has been the radar of many physicians for several years now – and brought into new relief by more recent changes such as the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) – is the Meaningful Use concept introduced by the Health Information Technology for Economic and Clinical Health (HITECH) Act.

“Meaningful Use” relates to physicians’ use of certified electronic health records (EHR) technology in the interest of interoperability and efficient electronic exchange of health information. The Centers for Medicare & Medicaid Services (CMS) offers an incentive program which offers incentive payments to eligible professionals and eligible hospitals who join and comply. Participation involves making “Meaningful Use Attestations” regarding compliance. Both compliance and noncompliance with Meaningful Use goals can represent a significant cost to physicians: compliance, as bringing a practice’s technological infrastructure up to the appropriate standards does not come cheaply; noncompliance, as those who choose not participate in CMS’s incentive program, face reductions in their Medicare and Medicaid payments. These reductions equal a 3 percent decrease in 2017.

It appears that noncompliance with Meaningful Use standards carries more of a bite than some observers may have thought. In June of 2017, the Office of the Inspector General (OIG) released a report that Medicare made hundreds of millions of dollars’ worth of incentive payments to Meaningful Use attesters who failed to meet the necessary requirements. The OIG estimated a total of approximately $730 million dollars in inappropriate payments – more than ten percent of the total payments. CMS’s blunder largely resulted from its failure to conduct adequate documentation review, thus rendering the self-attestations of professionals prone to abuse. Note, too, that CMS is not the only authority to make inappropriate EHR incentive payments: the OIG faulted Texas in August 2015 for making such wrongful payments in an amount over $15 million through its Medicaid program.

This does not, of course, amount to a windfall for the physicians who received the wrongful payments. The OIG’s recommendation to CMS includes directing CMS to recover the wrongful payments it has identified (a small sample of the total), and to seek to identify, and then recover, the rest of the inappropriately directed federal funds. As is characteristically the case, government overpayments cannot be retained by the recipient. Thus, the takeaway from CMS’s improper Meaningful Use largesse should not be an observation that the government has, up till now, not been adequately reviewing Meaningful Use documentation. Instead, it should be that one can, of course, expect such mistakes to be corrected when discovered and that it is even more important to get Meaningful Use compliance correct now. What has been done in the past by a physician may not actually have sufficed. Additionally, part of OIG’s recommendation to CMS was to educate eligible clinicians on proper Meaningful Use documentation requirements. Physicians should look for and take advantage of such education.

This need to double down on one’s Meaningful Use efforts comes at a time when the reimbursement system is shifting to MACRA. The Medicare EHR Incentive Program is no longer a standalone program –it has been combined through MACRA with the Physician Quality Reporting System and the Physician Value-based Payment Modifier into a single program, the Merit-based Incentive Payment System (MIPS) under the Quality Payment Program (QPP). Although hospital and Medicaid Meaningful Use programs are unaffected by MACRA, clinicians will make their Medicare Meaningful Use attestations through the QPP. This program still focuses on the use of Certified EHR Technology to support interoperability and healthcare quality objectives. The meaningful use measures are calculated and compensated somewhat differently under MIPS; one significant change is that a hybrid scoring system has replaced the previous all-or-nothing approach.

Although the manner of reporting Meaningful Use has changed somewhat, it has not become either less important or markedly simpler. Getting up to speed on the technological, administrative, and reporting features of establishing Meaningful Use now – when there is some clemency as far as timing goes worked into the transition period – is certainly advisable. The need to establish the goals of interoperability, efficiency, and care coordination that Meaningful Use seeks to advance is a need that is unlikely to diminish. The fact that CMS is now beginning to seek hundreds of millions of dollars in wrongful incentive payments only highlights that Meaningful Use compliance is an issue worth following in the always changing health care landscape.

Chris Thompson is an attorney with Burr & Forman LLP. Chris practices exclusively in the firm’s Health Care Practice Group. Burr & Forman, LLP, is an official Bronze Partner with the Medical Association.

Pin It

Tags: , , , , , , , ,

Posted in: MACRA

Leave a Comment (0) →

CMS Updates Proposed Rule for MACRA; Eases Burden for Some Physicians

Posted by on
CMS Updates Proposed Rule for MACRA; Eases Burden for Some Physicians

The Centers for Medicare & Medicaid Services has unveiled a 1,058-page proposed rule updating the Medicare physician payment system implemented under the Medicare Access and CHIP Reauthorization Act of 2015 with changes to make it easier for small independent and rural practices to participate.

The proposed rule would make changes in the second year of the Quality Payment Program as required by MACRA. According to a statement from CMS, the goal is to simplify the program, specifically for small, independent and rural practices, while ensuring fiscal sustainability and high-quality care within Medicare.

“We’ve heard the concerns that too many quality programs, technology requirements, and measures get between the doctor and the patient,” said CMS Administrator Seema Verma. “That’s why we’re taking a hard look at reducing burdens. By proposing this rule, we aim to improve Medicare by helping doctors and clinicians concentrate on caring for their patients rather than filling out paperwork. CMS will continue to listen and take actionable steps towards alleviating burdens and improving health outcomes for all Americans that we serve.”

The proposal will allow for the exemption of small providers participating in the program by increasing the low-volume threshold to $90,000 or less in Medicare Part B charges or 200 or less Medicare patients annually. The original threshold was $30,000 in Medicare Part B charges or 100 Medicare patients. The agency believes the move will exclude about 134,000 clinicians from MIPS.

American Medical Association President David Barbe released a statement commending the CMS for hearing the concerns of practicing physicians. “Not all physicians and their practices were ready to make the leap, and many faced daunting challenges. This flexible approach will give physicians more options to participate in MACRA and takes into consideration the diversity of medical practices throughout the country,” he wrote.

The news may come as a relief for some clinicians. In March, Healthcare Informatics found 43 percent of more than 2,000 providers stated they needed help with MACRA preparation while 30 percent said that are not prepared at all. However, after exclusions, CMS estimates 36 percent of clinicians will be eligible for participation in 2018.

The American Academy of Family Physicians stated the regulation would help improve family physicians’ ability to participate in payment reforms successfully.

“We’re pleased that, consistent with the Department of Health and Human Services’ directive, CMS has taken steps to reduce administrative and regulatory burden,” John Meigs Jr., M.D., president of AAFP, said in the statement. “We’re equally pleased that CMS agreed with the AAFP recommendations on medical homes. For example, the financial risk borne by medical homes rolls out more slowly, providing more time for family physicians to move toward full participation in the Advanced Payment Model track. Equally important are the significant steps to reduce risk for practices of all sizes in the MIPS program.”

 

New Quality Payment Program Resources Available

The Centers for Medicare & Medicaid Services revamped the look of the Quality Payment Program website and posted new resources to help you successfully participate in your first year of the Quality Payment Program. READ MORE

Pin It

Tags: , , , , , ,

Posted in: CMS, MACRA

Leave a Comment (0) →

New Quality Payment Program Resources Available

Posted by on
New Quality Payment Program Resources Available

The Centers for Medicare & Medicaid Services has revamped the look of the Quality Payment Program website and posted new resources to help you successfully participate in your first year of the Quality Payment Program.

CMS encourages you to visit the website to review the following new resources:

For more information, visit the Quality Payment Program website. The Quality Payment Program Service Center can also be reached at 1-866-288-8292 (TTY 1-877-715- 6222), available Monday through Friday, 8 a.m.-8 p.m. (ET) or by email at mailto:QPP@cms.hhs.gov.

Pin It

Tags: , , , , ,

Posted in: CMS

Leave a Comment (0) →

Questions about Your MIPS Participation Status?

Posted by on
Questions about Your MIPS Participation Status?

UPDATED MAY 18, 2017 — The Centers for Medicare & Medicaid Services announced all physicians required to participate in the Merit-based Incentive Payment System will receive notification of their participation status by the end of May. With the program already underway, status letters are considered by many to be long overdue.

CMS recently sent letters to 806,879 clinicians informing them they will not be evaluated under MACRA’s MIPS System for this year, according to a recent article in Modern Healthcare. Exempted doctors are those with less than $30,000 in Medicare charges and fewer than 100 unique Medicare patients per year. Physicians new to Medicare this year are also exempt. About 418,000 physicians will still need to submit MIPS data. The change came after the CMS used an updated formula to estimate providers’ Medicare revenue.

Physicians should soon receive a letter from your Medicare Administrative Contractor that processes Medicare Part B claims, providing the participation status of each MIPS clinician associated with your Taxpayer Identification Number (TIN).

Physicians should participate in MIPS in the 2017 transition year if they:

  • Bill more than $30,000 in Medicare Part B allowed charges a year and
  • Provide care for more than 100 Part B-enrolled Medicare beneficiaries a year

Starting in 2017, physicians can choose to participate in the new Quality Payment Program as a group or individually either through the MIPS or by participation in an Advanced Alternative Payment Model (APM). Physicians can earn a positive MIPS payment adjustment for 2019 if they submit 2017 data by March 31, 2018. Those who don’t submit the required data will receive a negative 4 percent payment adjustment. For more information, visit the Quality Payment Program online.

Physicians can now use an interactive tool on the Quality Payment Program website to determine if they should participate in 2017. To determine your status, enter your National Provider Identifier into the entry field on the tool and find out whether or not you should participate in MIPS this year and where to find resources. To get the latest information, visit the Quality Payment Program website. Contact the Quality Payment Program Service Center at 866-288-8292 (TTY 877-715- 6222) or email QPP@cms.hhs.gov.

Pin It

Tags: , ,

Posted in: CMS

Leave a Comment (0) →

Medical Association Urges CMS to Reduce EHR and MU Burden on Physicians

Posted by on
Medical Association Urges CMS to Reduce EHR and MU Burden on Physicians

The Medical Association has joined forces with the American Medical Association, Medical Group Management Association and 85 other medical groups to urge Centers for Medicare & Medicaid Services to reduce electronic health record and meaningful use requirements on physicians.

In a letter to new CMS Administrator Seema Verma, the groups first welcomed the new administration’s emphasis on reducing regulatory burdens on the house of medicine by acknowledging that the passage of the Medicare Access and CHIP Reauthorization Act, or MACRA, and the existing value-based purchasing programs affecting physicians, such as Meaningful Use, Physician Quality Reporting System and Value-based Payment Modifier needing streamlining and alignment. However, the administration was urged to take steps to address these same challenges in MU, PQRS and VM prior to their replacement by MACRA and minimize the penalties assessed for physicians who tried to participate in these programs.

“Eligible providers should not be penalized for focusing on providing quality patient care rather than the arbitrary ‘check the box’ requirements of MU. Creating an administrative burden hardship exemption would provide immediate relief for those impacted by the programs that predate MACRA,” the letter stated. “As indicated in the MACRA law and final regulations, policymakers in Congress and the Administration clearly understand that fair and accurate measurement of physicians’ performance will not be possible until better tools become available. We also believe the steps we have outlined are in keeping with President Trump’s efforts to reduce regulatory burden.”

See also Medical Association Joins Call to CMS to Delay EHR Certification Requirements

Pin It

Tags: , , , ,

Posted in: Advocacy

Leave a Comment (0) →
Page 2 of 4 1234