Medicare reimbursement undergoing big changes

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On April 27, 2016, CMS issued a Notice of Proposed Rulemaking (NPRM) to put in place key parts of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). This bipartisan legislation replaces the flawed Sustainable Growth Rage formula by paying clinicians for the value and quality of care they provide. This proposed rule will make changes through a single framework called the “Quality Payment Program”. The rule is expected to be finalized sometime this fall; however, in the proposed rule CMS has indicated a 2-year look back period, which means your performance in 2017 will determine your reimbursement in 2019 when the program is set to begin. To ensure our members have the information and resources to make this transition we have provided information below.

CMS Quality Payment Program

CMS Proposed Rule Executive Summary

AMA Medicare Payment Reform website

Here you’ll find information about the MACRA law, a checklist to prepare, and information to help you understand MIPS and APMS.

Practice Transformation Network

The PTN offers free resources to Kansas clinicians through the Compass Practice Transformation Network, led by the Kansas Healthcare Collaborative.

Postition paper from Texas Medical Association

Our friends at the Texas Medical Association created this helpful position paper which provides a summary of the upcoming changes and how it may affect physicians.

Contact Ruth Cornwall, KMS Director of Health Care Finance with any questions or concerns.


EHR Meaningful use attestation and hardships

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Physicians have until July 1, 2016 to apply for a hardship exemption from the electronic health record (EHR) meaningful use financial penalties for the 2015 program year. Those who don’t apply could see up to a 3 percent reduction in their Medicare payments in 2017 since the meaningful use program operates on a two-year look-back period.

CMS has stated that it will broadly grant hardship exemptions as a result of the delayed publication of the State 2 meaningful use modifications rule, which left physician little time to report under the modified program requirements issued last fall.

The American Medical Association encourages all physicians participating in the 2015 Medicare meaningful use program to apply for the hardship. Applying for the hardship will not prevent a physician from earning an incentive if they successfully attest to meaningful use. It simply protects a physician from receiving a meaningful use penalty. Therefore, physicians who believe that they met the program requirements for the 2015 reporting period and plan to attest by March 11, 2016, should still apply for the hardship exemption which will act as a safety net in the event you are an unsuccessful reporter. CMS has issued an FAQ supporting this.

The hardship application must be submitted before midnight Eastern Time on July 1, 2016. CMS has published additional information on the hardship exception instructions.

Physicians who decide not to file a hardship exemption must attest by March 11, 2016 10:59 p.m. CST. CMS has an Attestation Worksheet and User Guide available. Questions regarding attestation may be directed to the EHR Information Center Help Desk at 888.734.6433 and select option 1.

If you have any questions, contact Ruth Cornwall, KMS Director of Health Care Finance.


PQRS submission deadline approaching

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Eligible professionals who do not satisfactorily report quality measure data to meet the CMS 2015 Physician Quality Reporting System (PQRS) requirements will be subject to a negative 2 percent payment adjustment on all Medicare Part B Physician Fee Schedule services performed in 2017. As a reminder, the 2015 PQRS data submission deadlines are as follows:

  • EHR Direct or Data Submission Vendor – 3.11.16
  • Qualified Clinical Data Registries – 3.11.16
  • Group Practice Reporting Option – 3.11.16
  • Qualified Registries – 3.11.16
  • QCDRs – 3.31.16

For each deadline listed above, the submission ends at 7pmCST. CMS encourages organizations to submit data well in advance of 7CST to ensure it is fully submitted before the submission period closes.

For questions, please contact the QualityNet Help Desk at 1.866.288.8912 or via email at Complete information about PQRS is available here. You may also contact Ruth Cornwall, KMS Director of Health Care Finance for any questions or concerns.


2016 Medicare physician fee schedule

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CMS has released the final 2016 Medicare Physician Fee Schedule with comments. This rule updates payment and policies for the 2016 calendar year. The rule finalized a number of new policies, including several that are the result of the recently enacted Medicare Access and Children’s Health Insurance Program Reauthorization Act of 2015. These updates include modifications to the physician quality reporting system, the physician value-based payment modifier and the Medicare electronic health record incentive program.

The AMA has provided a summary of changes and can be found HERE.

Questions or concerns regarding this final rule with comment may be directed to Ruth Cornwall, KMS Health Care Finance at 785.235.2383 or


Act by December 16 to avoid Medicare pay cut

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December 14, 2015

If you submitted data to PQRS for the 2014 reporting period you should review your quality and cost reports. CMS uses the data in these reports to calculate your quality and cost performance score which determines how you’ll get paid under the 2016 Medicare Part B Physician Fee Schedule. According to an AMA news alert, “problems with how CMS has been collecting and analyzing data related to the PQRS and VBM programs are leading to inappropriate penalties of 2-4 percent of Medicare payments for thousands of physicians.”

If you’ve already reviewed your reports, KMS encourages you to check again for new and revised versions. If Medicare says you’ll receive the 2016 payment cut, or if you’re concerned about receiving a penalty you should file an appeal, know as an “informal review request,” by December 16 for each report you want to contest. This is the only appeals process Medicare has for the PQRS and VBM programs and the only opportunity you’ll have to appeal before the pay cuts take effect on January 1, 2016.

To access your reports:

Additional information about the process and contact information for questions is available in CMS’ informal review fact sheet.


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