As you may know, beginning January 1, 2012 a federal mandate requires providers, clearinghouses, and health plans to use new standards in electronically conducting certain healthcare administrative transactions including claims, remittance, eligibility and claims status requests. This new requirement mandates an upgrade from 4010A1 as the transaction standard, to the new 5010 standards.
The transition to 5010 will also mark one of the first steps in preparing administrative systems for the transition to the ICD-10. We are happy to report that we have tested and are ready to go live by the January 1, 2012 mandate, and look forward to a seamless transition.
On behalf of the entire team at RBS we wish you a healthy and thriving new year!
A comprehensive tool to help eligible professionals and physicians work their way through each phase of the Medicare Electronic Health-Record Incentive Program has been developed by CMS.
The new tool is called, “An Introduction to the Medicare EHR Incentive Program for Eligible Professionals”, which includes sections on program basics, eligibility and registration. Stage 1 Meaningful-Use Criteria is also discussed, and helps practitioners choose which optional measures they will use for the attestation phase of the program.
In an effort to induce more practitioners to attest this year, HHS Secretary Kathleen Sebelius announced that the CMS would change the deadline allowing one additional year for compliance with Stage 2 meaningful-use criteria. Until this announcement, physicians and other eligible professionals had until December 31, 2011, to complete 90 consecutive days of meaningful use of a certified EHR, and until February 28, 2012, to report their data and attest that they have met the criteria to be deemed meaningful users in the Medicare portion of the program.
Sebelius also announced that HHS would be looking for those professionals who may have registered EHR incentive payment program, but have not yet attested as meaningful users and using additional outreach, education and training programs to streamline EHR adoption.
Congressional leaders have agreed to include a two-year extension of the current Medicare physician pay rates, which includes a 1% increase, as part of a legislative package being negotiated mostly to extend the, soon to expire, payroll tax cut.
In an Interview, Rep. Phil Gingrey (R-Ga.), Co-Chair of the GOP Doctors Caucus, said that the two-year $38 billion extension of current rates that were scheduled to drop 27.4% on Jan. 1, 2012, “was not ideal” but was better than the sometimes months-long extensions that have occurred over the past two years, as Medicare's sustainable growth-rate funding formula has repeatedly called for steep physician payment cuts. Republican leaders had considered a shorter term, he said, but the caucus urged two years as the minimum.
Gingery implied that a permanent fix to Medicare’s payment formula would not happen this year, due to the current congressional focus on deficit reduction. The extension of the current pay rate would allow time to work on a more permanent solution over the next two years. Gingrey said he would prefer a model based on reimbursing the physician for meeting certain benchmarks in treatment, rather than a fee for service.
The House is expected to vote on the package before their December 19th adjournment for the holidays. Gingrey was uncertain if the Senate would support the package. In addition to agreeing to the pay rate extension, a letter from house members asking that hospital rehabilitation cuts not be included in a year end funding package was sent to 79 Republicans and Democrats earlier Thursday.
A recent survey by the National Center for Health Statistics (NCHS) conducted between February and June of this year indicates that nearly 57% of physicians responding to the survey were using electronic health records (EHR) in a capacity other than for billing. This represents a 6% increase from 2010 when usage was only reported at 50.7%. Additionally, 52% of respondents this year said that their practice was planning to apply for federal incentives linked to usage of EHR. The NCHS works as an arm of the Centers for Disease Control and Prevention (CDC) and has been tracking the adoption of EHR since 2008 as part of the National Ambulatory Medical Care Survey (NAMCS) program. These latest numbers were based on mail surveys compiled from a sample of about 10,300 physicians.
This year’s survey also showed marked increases in the use of “any” EHR system in the respondents adoption of the “basic” EHR systems. This year’s survey showed that more than one-third of those responding were using a basic EHR system in their practice, which is an increase from 2010 when less than 25% responded that they were using “any” of the EHR system.
The 2010 “basic” system lacked the capability to compile an allergy list, therefore fulfilling only seven functions; however the new definition in 2011 has added an allergy listing to the basic system. Missing from the 2011 report is a mention of adoption rates for “fully functional” EHR. A list of 16 functions was compiled through the work of Dr. David Blumenthal to constitute a fully functional EHR. They included all of the basic functions, but also listed advanced clinical decision-support features, such as clinical guidelines and drug-interaction alerts as well as interoperability functions, including the ability to electronically order lab and radiology tests. The 2010 report listed the penetration rate of a fully functional EHR at 10%.
Blumenthal’s researchers initially surveyed and found that the adoption level for fully functional EHR’s was 4%. With this information, they went back and gave partial credit to those physicians who were adopting a basic system with fewer functions which then moved the adoption level to 13%. This methodology was handed over to the NCHS for further use and survey work.
CMS will begin several new demonstration programs in the year 2012 whose purpose is to curtail improper Medicare payments.
California, Florida, Illinois, Louisiana, Michigan, New York, North Carolina, Ohio, Pennsylvania, and Texas will pilot prepayment reviews of claims, called the “Recovery Audit Contractor” (RAC) program, which will check for compliance on the part of the providers with the rules of Medicare. This program will also target certain claim types that historically have had more improper high payments. The RAC will initially focus on inpatient hospital claims for short stays, with additional claims to be selected by CMS.
In the second demonstration program, California, Florida, Illinois, Michigan, New York, North Carolina, and Texas will be required to gain authorization for certain medical equipment starting with power mobility devices.
The final demonstration program, Part A to Part B rebilling, is open to 380 hospitals nationwide who volunteered for the program. CMS will enable these hospitals to rebill for up to 90% of the Part B payment when a Part A claim is denied by a contractor on an inpatient short stay. These payments are currently denied in full when the incorrect setting is billed.
In the past week the American Medical Association voted to oppose the adoption of a new morbidity classification system that would be required by the U.S. Government in the near future.
The group representing about a quarter of all U.S. doctors voted to stop the implementation of the proposed ICD-10. The organization cites among other issues, poor timing, insignificant patient benefits, and high costs in making their determination.
AMA president Dr. Peter W. Carmel is quoted as saying, “the implementation of ICD-10 will create significant burdens on the practice of medicine with no direct benefit to individual patients’ care.”
The two systems ICD-10 and ICD-10-CM were developed by the WHO and would be replacing the more than 30 year old ICD-9 system. CMS is currently requiring all U.S. providers to upgrade to ICD-10-CM for diagnostic codes by October 1, 2013 with the hospitals being required to make the move to ICD-D-PCS by the same date if they want to get inpatient procedures reimbursed.
According to the American Health Information Management Association, the new codes have already been adopted by all other industrialized nations with the United States being the hold out. However, the transition could be difficult because the new system is perceived as being far more complex than ICD-9. For example, the current system uses around 13,000 diagnostic codes whereas the ICD-10-CM uses an approximate 68,000 codes. The complexity of the new system may also translate to a higher expense. The AMA recently did a study that showed a three-physician practice would have to spend more than $83,000 to implement the new program.
You may not have heard that CMS has announced today that it “will hold off until March 31, 2012, on enforcing its rule requiring hospitals, physician practices, health plans and claims clearinghouses to switch to using the ASC X12 Version 5010 standards for the electronic transmission of healthcare claims and other administrative communications."
See the press release at:
http://www.cms.gov/ICD10/Downloads/CMSStatement5010EnforcementDiscretion111711.pdf
On November 1, 2011, the Centers for Medicare & Medicaid Services (CMS) issued a final rule with comment period that will update payment policies and rates for furnished services under the Medicare Physician (MPFS) on or after January 1, 2012. The final rule makes changes to several incentive programs that are associated with MPFS payments – electronic health records (EHRs), and the Physician Quality Reporting System (PQRS) - as well as changes to the Physician Compare tool.
The Medicare and Medicaid EHR Incentive Programs requires eligible professionals (EPs), eligible hospitals, and CAHs to electronically submit clinical quality measure (CQM) results as calculated by certified EHR technology beginning in the 2012 payment year. The July, 2010, final rule implementing the program also stated that the primary method for these providers to report required CQM information electronically would be to log into a CMS-designated portal and submit data through an upload process. Under the MPFS final rule announced today, CMS finalizes the following methods for reporting CQM’s in order to demonstrate meaningful use by EP’s:
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Continue with attestation for reporting CQMs
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Participate in a PQRS-Medicare EHR Incentive Pilot, established in this 2012 MPFS final rule that relies on the infrastructure of the Physician Quality Reporting System. EPs could report CQMs vial the pilot through either of two methods:
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By using a PQRS-qualified EHR data submission vendor to submit calculated results from the EP’s certified EHR to CMS on the EP’s behalf; or
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By submitting CQM data directly from certified EHR to CMS through a secure portal. The EHR must also be a qualified PQRS EHR product.
Under the MPFS final rule, CMS finalizes the following requirements for PQRS in 2012:
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Group Practice Reporting Option for reporting PQRS:
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CMS defines a “group practice” as a group of 25 or more individual eligible professionals, and makes conforming changes to the criteria for satisfying the reporting requirements to reflect the change in the definition.
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The rule also finalizes 29 measures for reporting under the Physician Quality Reporting System GPRO in order to align with other CMS quality reporting programs.
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Individual Eligible Professional reporting:
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A PQRS core measure set (seven measures, one of which is available for EHR reporting only) aimed at the prevention of cardiovascular conditions;
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Finalizes 211 individual measures available for claims and/or registry reporting, including 26 new measures;
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All 44 EHR measures currently reportable in the Medicare EHR Incentive Program
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Includes a reporting option for EHR-based reporting that aligns with the reporting requirements for reporting CQMs under the EHR Incentive Program; and
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Allows for submission of the PQRS EHR measures through an EHR data submission vendor in addition to direct submission from an EP’s EHR-based product to CMS
Maintenance of Certification Program Incentive
Payment Adjustment for 2015
Section 10331 of the Affordable Care Act requires CMS to implement a plan for making information on physician performance publically available no later than January 1, 2013. This provision supports CMS’s overarching goals to foster transparency and public reporting by providing the consumer with information to make informed decisions about their health care, while encouraging clinicians to improve the quality of the care they provide to their patients.
The MPFS final rule announced today finalizes the proposed plan initially based on public reporting of performance rates for group practices that submitted data under the PQRS GPRO reporting option for the 2012 reporting period. CMS finalizes its proposal to report performance rates for other CMS demonstrations using group practice reporting on the Physician Compare web site as early as 2013.
The final rule with comment period will appear in the November 28, 2011 Federal Register. CMS will accept comments on those provisions subject to comment until January 3, 2011 and will respond in the MPFS for CY 2013.
The Centers for Medicare & Medicaid Services (CMS) today issued a final rule with comment period that updates payment policies and rates for physicians and non-physician practitioners (NPPs) for services paid under the Medicare Physician Fee Schedule (MPFS) in calendar year (CY) 2012.
CMS is required to issue a final rule that reflects current law. Under current law, providers will face steep across-the-board reductions in payment rates, based on a formula– the Sustainable Growth Rate (SGR) – that was adopted in the Balanced Budget Act of 1997. Without a change in the law from Congress, Medicare payment rates to providers paid under the MPFS will be reduced by 27.4 percent for services in CY 2012—less than the 29.5 percent reduction that CMS had estimated in March of this year because Medicare cost growth has been lower than expected. This is the eleventh time the SGR formula has resulted in a payment cut, although the cuts have been averted through legislation in all but CY 2002. The Obama Administration is committed to fixing the SGR and ensuring these payment cuts do not take effect.
In the CY 2012 final rule, CMS is expanding the potentially misvalued code initiative, an effort to ensure Medicare is paying accurately for physician services and more closely managing the payment system. This year, CMS is focusing on the codes billed by physicians in each specialty that result in the highest Medicare expenditures under the MPFS to determine whether these codes are overvalued. In the past, CMS has targeted specific codes for review that may have affected a few procedural specialties like cardiology, radiology or nuclear medicine but has not taken a look at the highest expenditure codes across all specialties. This effort results in increased payments for primary care services that have historically been undervalued by the fee schedule.
CMS is also making changes in how it adjusts payment for geographic variation in the cost of practice. The Affordable Care Act and the Medicare and Medicaid Extensions Act made some temporary adjustments that were in place for two years while CMS and The Institute of Medicine (IOM) began to comprehensively study these issues.
The final rule with comment period will appear in the November 28, 2011, Federal Register. CMS will accept comments on those provisions that are subject to comment until Dec. 31, 2011, and will respond in the MPFS for CY 2013.
Wondering what the course for this year's 5K Run for the Future to benefit the Radiation Oncology Institute will be like? Dan Moore fills you in: