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Tuesday, June 30, 2015

Place of service matters in Medicare billing

Last December, I reported that the U.S. Department of Health and Human Services Office of Inspector General (OIG) planned to examine place of service (POS) coding by physicians as part of its fiscal year 2015 work plan. Last month, the OIG revealed its findings: Medicare contractors overpaid physicians $33.4 million between January 2010 and September 2012 as a result of incorrect coding related to POS. Specifically, physicians were incorrectly paid for performing these services in non-facility locations, such as physician offices or independent clinics, when they were actually working at facility locations, such as ambulatory surgery centers (ASCs) or hospital outpatient centers.

The difference between a physician’s payment for services performed in the office and services performed in a facility can be significant. Physicians are paid more for professional services performed in their offices than those they perform at hospital outpatient centers and ASCs. When a physician performs in a facility like an ASC, Medicare pays the facility, not the physician, for the facility’s overhead expense. In turn, Medicare pays the physician less under the physician fee schedule because the physician did not have the overhead and much of the other practice expenses of the facility’s location of service.

In the end, it all boils down to the POS reported on the claim. When a physician provides an office-based service, the physician should bill with the correct POS code, generally a POS code 11. When a physician provides a facility-based service, the physician should bill the services with an appropriate POS code reflecting the type of facility, for example, a POS code 22 for hospital outpatient centers or a POS code 24 for ASCs.

So, what can your practice do to avoid such errors? OIG’s report made a number of suggestions, including making sure:

• Billing staff is clear about the definition of “physician’s office” or other non-facility locations and understands the need to code POS appropriately.

• Billing staff is aware that the POS code can affect Medicare payment and that inaccurate use of non-facility POS codes can mean potential Medicare overpayments.

• Billing systems are not designed to submit all physician professional service claims with a non-facility POS code.

• You implement internal controls to identify potential coding errors before claim submission.

As noted, inaccurate use of POS codes can lead to Medicare overpayments, which, in turn, can lead to overpayment recovery efforts on the part of the Centers for Medicare & Medicaid Services (CMS) and its contractors. For instance, based on its findings, OIG recommend that CMS direct its Medicare contractors to initiate, in accordance with CMS policies, the immediate recovery of $7.3 million in potential overpayments from physicians who incorrectly coded physician services performed in ASCs and $19 million in potential overpayments related to the services that may have been performed in hospital outpatient locations. That’s in addition to the $7.1 million in potential overpayments 87 physicians told CMS they intended to pay back for incorrectly coding physician services performed in hospital outpatient locations.

OIG also recommended that CMS and its contractors continue to educate physicians and billing personnel on the importance of internal controls to ensure the correct POS coding for physician services. Finally, OIG recommended stronger and wider efforts to perform coordinated data matches of non-facility-coded physician services and facility claims to identify physician services that are at a high risk for POS miscoding and recover the overpayments that are identified as a result.

All of which means a likely greater focus and scrutiny on POS coding going forward, especially since this is not the OIG’s first inquiry into POS billing.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Friday, June 26, 2015

MACRA changing rules for opting out of Medicare

The Medicare Access and CHIP (Children’s Health Insurance Program) Reauthorization Act of 2015 (MACRA) is simplifying the process that physicians must follow to opt out of Medicare.

Before the law went into effect this spring, the opt-out affidavits that physicians and other providers signed had to be renewed every two years for the opt-out status to continue. Beginning with valid opt-out affidavits signed on or after June 16, 2015, the affidavits will now renew automatically every two years. Physicians who don’t want their affidavit to automatically renew need to notify in writing all Medicare Administrative Contractors (MACs) with which they filed an affidavit. This notification must occur at least 30 days before the start of the next opt-out period.

Affidavits filed before June 16 will expire at the end of two years as before. Physicians wanting to extend the opt out must file to all applicable MACs a renewal affidavit within 30 days after the current opt-out period expires.

For more information on opting out of Medicare, including the effects on contractual obligations and finances, see the article “How to Say Goodbye to Medicare” from the FPM archives.

Friday, June 19, 2015

Study finds no clear winner among Medicare payment models

As Congress considers how to make Medicare spending more efficient and cost-effective, a new study has found it won’t be as easy as picking a single payment model.

The Medicare Payment Advisory Commission, which advises Congress on Medicare, has filed its annual report. Following up on similar research started last year, the group looked at the performance of the three main payment models: fee-for-service (the standard model tied to the provision of tests and procedures), Medicare Advantage (capitated payments per member), and accountable care organizations (groups of physicians and other providers that share in savings and risk).

The commission said it found that no one model performed the best across all 78 markets it studied, with fee-for-service being cheapest in 28 markets, ACOs cheapest in 31 markets, and Medicare Advantage cheapest in 19 markets. Researchers noted there are still few studies comparing the quality and patient satisfaction generated by the three models.

The report said that Medicare may need to change its payment rules to encourage recipients to choose the payment model that is cheapest for their market. For instance, Medicare could set a national base premium for Part-B services that would pay for either fee-for-service/ACOs or Medicare Advantage, whichever was cheaper in a particular market. Or it could calculate premiums at the market level, with higher spending markets having higher premiums, which would again pay for whichever model was cheapest. Note that the researchers folded ACOs in with fee-for-service for this exercise.

The commission also continued to express concerns about how Medicare measures care quality, saying it relied too much on clinical processes that didn’t necessarily lead to better health outcomes and sometimes placed a heavy reporting burden on physicians and other providers. Among the commission's alternatives is a new measure called “healthy days at home,” which measures the number of days during a specific period where a recipient was alive and didn’t interact with the health care system, other than for preventive or maintenance care.

Initial analysis indicates this measure could highlight meaningful differences in health outcomes across populations, especially when applied to patients with one or more chronic conditions. But the researchers also said the measure needed more study to determine if differences in post-acute-care were skewing the results and reflecting differences in practice patterns across geographic areas rather than differences in health status.

Thursday, June 11, 2015

Feds warn about potentially illegal medical director compensation

Federal investigators are warning physicians who serve as medical directors to make sure their compensation agreements aren't violating anti-kickback regulations.

The Department of Health and Human Services' Office of Inspector General (OIG) this week said it recently reached settlements with a dozen physicians across the country who had served as medical directors for various health care organizations. The agency said it determined those physicians' directorship compensation agreements were improper because they were tied to the individual physicians' volume or value of referrals and didn't reflect fair market value of the services they rendered – if they provided any services at all.

In some cases, the physicians also entered agreements that led to an affiliated hospital, health group, or other entity paying the salaries of the physician's office staff. While not paying the physician directly, these arrangements reduced the physicians' actual business expenses, so the inspectors claimed this compensation improper.

The OIG reminded physicians that a compensation arrangement is potentially illegal if any part of it compensates the physician for past or future referrals of federal health care program business. For more information, see "OIG compliance program guidance for individual and small group physician practices" and "A roadmap for new physicians: avoiding Medicare and Medicaid fraud and abuse."

Tuesday, June 9, 2015

New payment model seeks to reduce cardiovascular disease

The Centers for Medicare & Medicaid Services (CMS) is accepting applications from physicians and other health care providers to test a new model for reducing the risk of cardiovascular disease among Medicare beneficiaries.

The Million Hearts Cardiovascular Disease (CVD) Risk Reduction model will pay participating practices to help beneficiaries determine their individual risk for heart attack or stroke over the next 10 years. It will then pay those practices to help high-risk patients identify the best ways to reduce their individual risk factors and encourage them to make those changes, hopefully leading to lower rates of heart attack and stroke in those patients.

CMS plans to operate the Million Hearts CVD Risk Reduction for five years and involve more than 300,000 Medicare beneficiaries and 720 practices. The practices will vary in size and patient case mix and can include physicians in family medicine, general practice, general internal medicine, geriatric medicine, multi-specialty care, or cardiovascular care. Half of the selected practices will actually participate in the model while the other half will serve as control practices.

To be eligible, participating practices must have:

•    At least one provider, which CMS defines as a medical doctor, doctor of osteopathic medicine, physician assistant, or nurse practitioner; 
•    An electronic health record (EHR) system certified by the Office of the National Coordinator for Health Information Technology; and
•    Met the criteria for Stage 1 of Medicare’s meaningful use EHR incentive program.

But how much are you paid? Under the program, each practice chosen to implement the intervention will receive a onetime payment of $10 per Medicare beneficiary in the target population to perform the initial risk stratification. Once the practice has identified the individuals at high risk for CVD, it will receive $10 per beneficiary per month to work with those patients to reduce their risk. CMS may potentially reduce those payments to a practice beyond the first year depending on how well the practice is reducing the beneficiaries' CVD risk. Practices chosen for the control group will receive an annual one-time payment of $20 per Medicare beneficiary in the target population for successfully submitting their data.

If your practice is interested in applying, you must first submit a non-binding letter of intent (LOI) by Sept. 4. CMS will use letters of intent for planning purposes only. Once CMS receives the LOI, practices will have until 11:59 p.m. (EST) Sept. 4 to electronically submit the application. You can access application materials at http://innovation.cms.gov/initiatives/Million-Hearts-CVDRRM/.

For more information on this new payment model, please review the fact sheet and frequently asked questions on the CMS web site.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Thursday, June 4, 2015

Claims acceptance rate rises in latest ICD-10 end-to-end test

With less than four months to go before the transition to ICD-10 coding, the Centers for Medicare & Medicaid Services (CMS) is continuing to make sure the system is ready.

Its latest round of end-to-end testing showed the percentage of failed claims narrowing, most of which it said were caused by technical problems not connected to the new ICD-10 codes.

Between April 27 and May 1, around 875 physicians, other health care providers, and billing companies volunteered to send test claims. Unlike ICD-10 acknowledgement testing, which simply determines if the tester’s claim is accepted or rejected, the end-to-end tests process the claims through all Medicare system edits and provide an Electronic Remittance Advice.

CMS said it accepted 88 percent of the 23,138 test claims submitted, which was an increase from the 81 percent accepted during the end-to-end test conducted earlier this year. It said 2 percent of the claims failed for using an invalid ICD-10 diagnosis or procedure code and less than 1 percent failed for using an ICD-9 code.

Other claims were denied for technical problems, such as using an incorrect National Provider Identifier (NPI), Health Insurance Claim Number, Submitted ID, or HCPCS code, using a date of service outside the valid range for testing, or using an invalid place of service.

CMS said it identified a coding issue involving inpatient hospital claims, which it will fix, and test filers will be allowed to resubmit those claims. An issue with home health claims identified in the January test has been fixed, CMS said.

The final end-to-end testing will be conducted July 20-24.

Tuesday, June 2, 2015

Not all valid vaccine codes are in the book

Vaccine development and subsequent approval by the Food and Drug Administration (FDA) does not always nicely coincide with publication of the Current Procedural Terminology (CPT) manual. Consequently, the American Medical Association (AMA) uses its website to feature updates to the codes for these products, based on actions taken by the CPT Editorial Panel and the FDA.

In general, once approved by the CPT Editorial Panel, AMA makes vaccine CPT codes available for release twice a year, on July 1 and Jan. 1. As part of this electronic distribution, there is a six-month implementation period from the initial release date (i.e., codes released on Jan. 1 are eligible for use on July 1, and codes released on July 1 are eligible for use Jan. 1). In case you missed them, we will discuss some vaccine codes and code changes that do not yet appear in the CPT manual.  

First, the AMA released new codes 90620, for “Meningococcal recombinant protein and outer membrane vesicle vaccine, Serogroup B, 2 dose schedule, for intramuscular use,” and 90621, for “Meningococcal recombinant lipoprotein vaccine, Serogroup B, 2 or 3 dose schedule, for intramuscular use,” on Nov. 1, 2014, for implementation Feb. 1, 2015. Payers may have decided to acknowledge and implement both codes for reporting purposes prior to Feb. 1, but from a CPT perspective, they are now available to use, even though they won’t appear in the CPT manual until 2016. Both vaccines are FDA-approved.

Similarly, the AMA released new code 90697, for “Diphtheria, tetanus toxoids, acellular pertussis vaccine, inactivated poliovirus vaccine, Haemophilus influenza type b PRP-OMP conjugate vaccine, and hepatitis B vaccine (DTaP-IPV-Hib-HepB), for intramuscular use,” on July 1, 2014, for implementation on Jan. 1, 2015. This vaccine is not yet FDA-approved, and the new code will appear in the 2016 CPT manual.

The 2015 CPT manual does include a new code, 90630, for “Influenza virus vaccine, quadrivalent (IIV4), split virus, preservative free, for intradermal use,” and a new code, 90651, for “Human Papillomavirus vaccine types 6, 11, 16, 18, 31, 33, 45, 52, 58, nonavalent (HPV), 3 dose schedule, for intramuscular use.” Both codes are designated in the manual as not yet having FDA approval. However, the product represented by 90630 received FDA approval on Dec. 11, 2014, and the product represented by 90651 received FDA approval on Dec. 10, 2014. The 2016 CPT manual will reflect their FDA approval status.

As a reminder, the codes above only identify the vaccine product. To report the administration of a vaccine/toxoid product, you will need to use an appropriate CPT immunization administration code (e.g., 90460, “Immunization administration through 18 years of age via any route of administration, with counseling by physician or other qualified health care professional; first or only component of each vaccine or toxoid administered”) or an appropriate Healthcare Common Procedure Coding System code, such as G0008, “Administration of influenza virus vaccine.”

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Thursday, May 28, 2015

CMS to change access to PQRS data in July

The Centers for Medicare & Medicaid Services (CMS) is changing how physicians and others access its computer system on July 13, a move that will particularly affect Physician Quality Reporting System (PQRS) participants and their staff.

Specifically, CMS is retiring the Individuals Authorized Access to CMS Computer Services (IACS) system. Current IACS user accounts will transition to another existing CMS system called Enterprise Identity Management (EIDM). The EIDM system allows CMS business partners to access multiple CMS applications.

CMS will move existing PQRS IACS users, their data, and roles to EIDM, all of which will be accessible from the “PQRS Portal” portion of the CMS Enterprise Portal. Users will then access the PQRS Portal to submit data (as needed), retrieve submission reports, view feedback reports, or conduct various administrative and maintenance activities. New PQRS users will need to register for an EIDM account.

CMS has promised more information and resources in the coming weeks. In the meantime, please make sure that your IACS account is active and current and that you’re able to log in. This will help ensure a smoother transition to EIDM. For additional assistance regarding IACS or EIDM, you can contact the QualityNet Help Desk at 1-866-288-8912 (TTY 1-877-715-6222) from 7:00 a.m. to 7:00 p.m. (Central Time) Monday through Friday, or via email at qnetsupport@hcqis.org.  

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Thursday, May 21, 2015

July 1 deadline approaching to avoid 2016 Medicare cut

Physicians who did not successfully participate in the Centers for Medicare & Medicaid Services’ (CMS) Electronic Health Record Incentive Program (also known as "meaningful use") in 2014 are scheduled to see their Medicare payments cut in January 2016.

However, those physicians can avoid a cut if they apply for a hardship exception by July 1.

To qualify for a hardship exception, you must show CMS proof that a specific circumstance beyond your control significantly prevented you from complying with the requirements of the program.

You can download instructions and applications (both for individuals and groups) for the hardship exception on CMS’s Electronic Health Record Incentive Programs website.

CMS will review each hardship application and supporting documentation to determine if an exception is warranted.

Newly practicing physicians, hospital-based physicians, and physicians with certain Medicare Provider Enrollment, Chain, and Ownership System (PECOS) specialties (i.e., anesthesiology, pathology, diagnostic radiology, nuclear medicine, and interventional radiology) do not have to apply for a hardship exception. CMS will use Medicare information to determine if these physicians are eligible for an automatic exception.

A hardship exception applies only to the 2016 payment adjustment. You’ll have to submit another, separate application for subsequent years.

Tuesday, May 19, 2015

More answers to questions about chronic care management

The Centers for Medicare & Medicaid Services (CMS) this month released a set of frequently asked questions (FAQs) about the chronic care management (CCM) service for which Medicare began paying this year.

The FAQs reaffirm some of what was already known about CCM and clarify other areas. For instance, regarding date of service and when to submit claims for CCM, answer No. 4 states, in part, “practitioners may bill . . . at the conclusion of the service period or after completion of at least 20 minutes of qualifying services for the service period. When the 20 minute threshold to bill is met, the practitioner may choose that date as the date of service, and need not hold the claim until the end of the month.”

The CMS FAQs also clarify the prohibition on reporting CCM for “facility” patients. For instance, answer No. 6 notes, in part, “CPT code 99490 cannot be billed . . . for services provided to [skilled nursing facility] inpatients or hospital inpatients, because the facility is being paid for extensive care planning and care coordination services.” The answer goes on to say, however, that if the patient is not an inpatient the entire month, time that is spent furnishing CCM services to the patient while he or she is not an inpatient can be counted towards the minimum 20 minutes of service time that is required to bill for that month. Several other questions and answers address when it is acceptable to report CCM under the Medicare hospital outpatient prospective payment system.

Like the CMS fact sheet on CCM, the CMS FAQs emphasize that CCM must be initiated by the billing practitioner during a comprehensive evaluation and management (E/M) visit, annual wellness visit, or initial preventive physical exam (i.e., Welcome to Medicare visit). During an open door forum call for physicians, nurses, and allied health professionals on May 13, CMS staff clarified that, for purposes of CCM, “a comprehensive E/M visit” could be any face-to-face E/M service with a physician, including 99212-99214.

For more information on Medicare’s CCM service, including links to related content in Family Practice Management, check out the related web page on the American Academy of Family Physician’s web site.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family 

Wednesday, May 13, 2015

Testing, testing – check your ICD-10 readiness

Physicians who still would like to participate in the final scheduled test of whether they are ready to use ICD-10 codes ahead of this fall’s deadline are getting another opportunity.

The Centers for Medicare & Medicaid Services (CMS) is accepting additional volunteers for the ICD-10 end-to-end testing scheduled for the week of July 20-24. Volunteers will be able to apply from May 11-22. This appears to be the last chance to test coding systems with Medicare Administrative Contractors (MACs) and the Common Electronic Data Interchange (CEDI) prior to the Oct. 1 implementation date.

CMS will select approximately 850 volunteer submitters to participate in the July end-to-end testing. The selected volunteers will represent a broad cross-section of provider, claim, and submitter types, including claims clearinghouses that submit claims for large numbers of providers. Testers who participated in the January and April end-to-end testing weeks are able to test again in July without re-applying.

Volunteer forms are available on your MAC website, and you will need to complete your form by May 22 to volunteer as a testing submitter. CMS will review applications and select additional July testers, after which the MACs and CEDI will notify the volunteers selected to test and provide them with the information needed for the testing by June 12.

If you are selected, you must be able to submit future-dated claims. You must also be able to provide valid National Provider Identifiers (NPIs), Provider Transaction Access Numbers (PTANs), and beneficiary Health Insurance Claim Numbers that will be used for test claims. This information will be needed by your MAC for set-up purposes by the deadline on your acceptance notice. Testers will be dropped if information is not provided by the deadline.

For more information on end-to-end testing, look at these MLN Matters articles:
•    “ICD-10 Limited End-to-End Testing with Submitters for 2015”
•    “FAQs – ICD-10 End-to-End Testing”
•    “Medicare FFS ICD-10 Testing Approach”

Whether or not you are selected for end-to-end testing, you can still participate in acknowledgement testing with the MACs and the Durable Medical Equipment (DME) MAC CEDI contractor anytime before Oct. 1. Additionally, CMS has scheduled a dedicated ICD-10 acknowledgement testing week June 1-5, during which submitters will have access to real-time help desk support. This is the final dedicated acknowledgement testing week.

MLN Matters Special Edition Article SE1501 explains the differences between acknowledgement and end-to-end testing with Medicare. For acknowledgement testing, all electronic submitters are encouraged to participate, even if you submit claims through a clearinghouse. You can also find more information in the MLN Matters article “ICD-10 Testing - Acknowledgement Testing with Providers.”

Information on how to participate in acknowledgement testing is available on your MAC website or through your clearinghouse (if you use a clearinghouse to submit claims to Medicare). Any provider who submits claims electronically can participate in acknowledgement testing.

Here’s what you can expect during acknowledgement testing:
•    Test claims will receive the 277CA or 999 acknowledgement as appropriate, to confirm that the claim was accepted or rejected in the system.
•    Test claims will be subject to all current front-end edits, including edits for valid NPIs, PTANs, and codes, including Healthcare Common Procedure Coding System and place of service codes.
•    Testing will not confirm claim payment or produce a Remittance Advice (RA).
•    MACs and CEDI will be staffed to handle increased call volume during this week.

When doing acknowledgement testing, make sure test files have the "T" in the ISA15 field to indicate the file is a test file, and send ICD-10 coded test claims that closely resemble the claims that you currently submit. Also, use valid submitter identification, NPI, and PTAN combinations plus current dates of service on test claims. Do not use future dates of service, or your claim will be rejected.

For more information about ICD-10, please visit the ICD-10 and Medicare fee-for-service provider resources web pages on the CMS web site, and for help preparing for ICD-10 implementation, please visit the coding web page on the AAFP web site.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Thursday, May 7, 2015

Mid-year quality reports from CMS provide a glimpse of the real thing

This fall, the Centers for Medicare & Medicaid Services (CMS) will release the 2014 Annual Quality and Resource Use Reports (QRURs) for all solo physicians and medical groups who submitted claims to Medicare during calendar year 2014.

These reports examine patient outcomes and cost information, which in turn will be used to calculate the 2016 Value Modifier.

In the meantime, CMS last month released the 2014 mid-year QRUR to physicians and medical groups. It measures performance on care provided between July 1, 2013, and June 30, 2014, meaning it contains only part of the information that will be in the annual report – and count toward the value modifier.

Still, CMS sees the mid-year report as a good resource for physicians and groups to identify areas where they need to improve their quality and efficiency. In fact, CMS has provided a guide on how to use your mid-year QRUR.

If you haven’t looked at your own mid-year report, you can find information to do so on the How to Obtain a QRUR web page.

Tuesday, May 5, 2015

Time to bust some ICD-10 myths

There continue to be some significant myths among family medicine practices as they prepare to implement ICD-10 in October. This week, I will attempt to debunk some of these myths for you.

Myth:    Another delay in implementation is inevitable.   
Fact:    Under current law, the ICD-10 transition date remains Oct. 1, 2015, and the Centers for Medicare & Medicaid Services (CMS) plans to implement ICD-10 on that date. Based on experience and the our natural inclination to procrastinate, it is tempting to believe this will be pushed back again. CMS has made it clear, however, that the government, payers, and large providers have made a substantial investment in ICD-10 and that this cost will rise if the transition is delayed. So expect CMS to implement ICD-10 on time to avoid an unnecessary increase in health care costs.

Myth:    There will be a “grace period” for submitting ICD-9 codes for dates of services on or after Oct. 1, 2015.
Fact:    Only claims coded with ICD-10 can be accepted for services provided on or after Oct. 1. Claims filed with something other ICD-10 codes on or after that date will not be accepted.

Myth:    Family medicine practices will have to use 68,000 ICD-10 codes.
Fact:    The typical family medicine practice does not use all 13,000 diagnosis codes available in ICD-9, and it will not be required to use the 68,000 codes that ICD-10 offers. As you do now with ICD-9, your practice will likely use only a small subset of the codes available in ICD-10.

Myth:    Family medicine practices will have to learn a completely new process for finding diagnosis codes.
Fact:    You will use a similar process to look up ICD-10 codes that you use with ICD-9. Increasing the number of diagnosis codes and changing the way those codes are structured does not necessarily change the way you find a code. As with ICD-9, ICD-10 has an alphabetic index that helps with code selection, and electronic tools are available to help with code selection, just as there are now with ICD-9.

Myth:    ICD-10 changes the way physicians report the services that they provide.
Fact:    For physicians, ICD-10 only changes diagnosis coding. It does not affect the use of Current Procedural Terminology (CPT) and the Healthcare Common Procedure Coding System (HCPCS) for physician claims. Your practice will continue to use CPT and HCPCS to report physician services.

Myth:    ICD-10 will affect how much physicians are paid for their services on a fee-for-service basis.
Fact:    Medicare and most private payers’ fees are pegged to the CPT or HCPCS code submitted, not the diagnosis code, and as noted, CPT and HCPCS codes are not changing on Oct. 1. As with ICD-9 diagnosis codes, ICD-10 diagnosis codes may sometimes be used to determine coverage or medical necessity of a particular service; however, beyond that, they should not affect the payment amounts for covered services.

For more facts about ICD-10, please visit the ICD-10 web page on the CMS web site, and for help preparing for ICD-10 implementation, please visit the coding web page on the AAFP web site.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family 

Thursday, April 30, 2015

Top 5 things to know about Meaningful Use Stage 2 changes

Earlier this month, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that included numerous changes to its Electronic Health Record (EHR) Incentive Program, also known as “Meaningful Use.”

The proposed guidelines are hundreds of pages long. So what is there to know without reading the voluminous rule? Here are five key takeaways from the new rule, which won’t be final until this fall but will affect Meaningful Use for 2015:

• Practices will no longer have to provide information on 10 measures that have been judged redundant, duplicative, or widely adopted. They include imaging results, family health history, electronic notes, patient list, patient reminders, clinical summaries, structured lab results, vital signs, smoking status, and patient demographics.
• The threshold for showing that a practice is successfully providing patients with electronic access to records will change from 5 percent of all patients to at least one patient.
• Showing that a practice is successfully providing patients with secure messaging options will change from meeting or exceeding a threshold of 5 percent of patients to a simple “yes or no” question.
• In 2015, all practices, regardless of when they started meaningful use, can show they are compliant using 90 days of data, as opposed to a full calendar year of data.
• In 2017, all practices, regardless of when they started meaningful use, must report a full calendar year of data to show compliance.

– Steven Waldren, MD, director of the Alliance for eHealth Innovation at the American Academy of Family Physicians

Tuesday, April 28, 2015

New PQRS reporting option for groups is now open

Physician groups wanting to avoid a 2 percent cut in Physician Quality Reporting System (PQRS) payments in 2017 have a new path to follow.

Registration is now open for groups with two or more eligible professionals to participate in the 2015 PQRS Group Reporting Option (GPRO) via the Physician Value - Physician Quality Reporting System (PV-PQRS). More information is available on the PQRS Payment Adjustment Information web page.

Groups can participate in the PQRS program for the 2015 performance period by selecting one of the GPRO reporting mechanisms between now and June 30:
•    Qualified PQRS Registry
•    Direct Eelectronic Health Record (EHR) using certified EHR technology (CEHRT) or CEHRT via Data Submission Vendor
•    Web Interface (for groups with 25 or more eligible professionals only)

Reporting the Consumer Assessment of Health Providers and Systems (CAHPS) for PQRS through a Centers for Medicare & Medicaid Services (CMS)-certified survey vendor is available to group practices taking part in PQRS under the GPRO in 2015 to supplement their PQRS reporting. This method is available to group practices of two or more eligible professionals. See CAHPS for PQRS Made Simple for complete details.

Meeting reporting requirements under PQRS in 2015 doesn’t just help avoid a PQRS pay cut in 2017, however. Failing to meet performance requirements this year also affects the Value Modifier in 2017 and could lead to an additional cut of 2 percent or 4 percent, depending on practice size. Satisfactorily reporting via PQRS GPRO is one of the ways groups can avoid automatic downward adjustments and potentially qualify for performance-based payment incentives under the Value Modifier. See What Physicians Need to Do in 2015 for the 2017 VM on the Value Modifier web page for more information.

Physician groups with two or more eligible professionals that choose not to register for GPRO may still avoid the automatic 2017 Value Modifier pay cut if they ensure that at least 50 percent of the eligible professionals in the group meet the criteria to avoid a 2017 PQRS payment adjustment as individuals.

You can access the Registration System for GPRO using a valid Individuals Authorized Access to the CMS Computer Services (IACS) account, and CMS provides instructions for obtaining an IACS account with the correct role on the PQRS GPRO Registration web page. CMS also provides instructions for registering to participate in the 2015 PQRS GPRO in the 2015 PQRS GPRO Registration Guide.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

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The views expressed here do not necessarily reflect the opinion of FPM or the AAFP. Some payers may not agree with the advice given. This is not a substitute for current CPT and ICD-9 manuals and payer policies. See Terms of Use.

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