Did you (or will you) get "the letter"?!
by Leigh-Ann Renz, 1/6/15
CMS to penalize Medicare practices for MU and PQRS non-compliance
Did you get the letter??
Did you - or will you - get he dreaded letter from CMS!? If you are an EP (eligible professional) who chose not to particpate in the MU (Meaningful Use) program, your Medicare reimbursements may be docked 1% in 2015 and each year going forward, up to 5%.
If you don't participate in the mandatory PQRS reporting program for Medicare, you could incur additional penalties of 1.5-2%. This means some practices will be hit with penalties of 7% within the next 5 years!
Some practices are receiving PQRS letters now: that their reimbursements will be docked in 2015. Don't forget that PQRS adjustments are staggered for 2 years: penalties levied in 2015 are for not reporting 2013 PQRS data. If you fail to meet the reporting deadline for 2014, you'll be penalized on your 2016 reimbursements. Click here for a quick PQRS overview or here for a detailed look.
Are mental / behavioral health + substance abuse providers subject to the penalties?
To be an EP, you must be an MD, DO, or NP - many mental heath providers do not prescribe medications and therefore are not subject to participation in the program. However, if you do meet this designation, you need to see if you qualify. For Medicaid, you must have at least 30% of your total reimbursements through Medicaid. For Medicare, there is no percentage threshold - and for Medicare Part B or Railroad, you must report PQRS. PQRS penalties are 1.5% for not reporting in 2013 (administered in 2015) and 2% for not reporting in 2014 (administered in 2016).
What to do if you have received a letter?
Approximately 55,000 EPs were approved for hardship exemptions earlier this year by CMS. About 2,000 applicants were denied the exemption on the basis of misunderstanding: "according to agency officials, [the providers] had actually already met the Meaningful Use threshold and were simply confused by the rule."
Those EPs who were granted hardship exemptions for 2015 penalties will need to reapply for 2016 exemptions if they expect to not meet the threshold again. "We can only grant hardships on a case-by-case and annual basis," a CMS official said in a recent press call. Click here for the CMS payment adjustment tip sheet.
What if you don't qualify for MU but do need to report for PQRS?
There are several methods to report PQRS. If you haven't been reporting via g-codes on your claims (and don't have enough unbilled claims from 2014 to meet the 50% threshold), you can report for the year via a PQRS registry. This will allow you to avoid the penalty (and perhaps even qualify for the 1.5% incentive; 2014 is the last year it is being offered). Click here for details.
Update 1.17.15: Subpoena Letters
Apparently, there are also a lot of Medicare and Medicaid Subpoena letters being received at this time. This is a completely different matter! Click here for details.