By Jim Tate, EMR Advocate
Meaningful Use Audit Expert
Twitter: @JimTate, eMail: Inquiry@meaningfuluseaudits.com
January 1, 2017 was coming fast and furious. The start of the 2017 MACRA reporting period would be affecting Part B Medicare reimbursement in 2019. No one was ready for the kick-off of the most radical change to Medicare Part B reimbursement in decades. How could they be? The Final Rule was not scheduled to be released until sometime around November 1st. I’m convinced the majority of Part B providers have no knowledge of the MACRA/MIPS program. Last Thursday relief came in the form of a valentine sent by CMS Acting Administrator Andy Slavitt. He announced that CMS intended to modify the 2017 reporting period. A collective sigh was heard across fruited plain.
In a blog post dated September 8, 2016 four different options were offered for 2017. The lowest level being to “Test the Quality Payment Program” as described in the following text: “With this option, as long as you submit some data to the Quality Payment Program, including data from after January 1, 2017, you will avoid a negative payment adjustment. This first option is designed to ensure that your system is working and that you are prepared for broader participation in 2018 and 2019 as you learn more.” Just what will define “some data” and outline a reporting period is not yet known. On a 10-point effort scale this seems to be between 0 and 1. Part B providers who take this path in 2017 will not earn any bonuses in 2017 but they will not be subject to penalties (AKA “fee adjustments). I’m betting most affected providers will choose this route and let the clarification and guidance trickle out over the next year allowing time for the process to mature before finalizing MACRA/MIPS strategies.
As always, the folks at HIMSS have provided a timely outline of all 4 options as presented in the announcement. Until more details are released I suggest taking a look at their initial take on the news.
Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. His unique combination of skills has brought successful outcomes to hospitals at risk of having their CMS EHR incentives recouped. He led the first appeal challenge in the nation for a client hospital that had received a negative audit determination. That appeal was decided in favor of the hospital. He has also been successful in leading the effort to reverse a failed appeal, even after the hospital had received notification of the failure with the statement, “This decision is final and not subject to further appeal”. That “final” decision was reversed in less than a week. If you are a hospital with questions or concerns about the meaningful use audit process, contact him at: Inquiry@meaningfuluseaudits.com.