MGMA receives numerous questions from members struggling to understand the myriad of Medicare quality reporting programs. To help practices navigate these complex requirements, the Association has created the PQRS-Value Modifier Survival Guide. This member-benefit leads you through the various reporting mechanisms in PQRS and the requirements that accompany them. The guide also reviews criteria for earning incentives and avoiding penalties in the programs and deciphers the critical connection between PQRS and the Value Modifier, which will impact all groups with 10 or more eligible professionals in 2016, based on 2014 performance.
Visit our PQRS Resource Center to access this member-exclusive tool and arm your practice with the knowledge to be successful in these programs.
EHR attestation deadline extended to March 31
The Centers for Medicare & Medicaid Services (CMS) is extending the deadline for eligible professionals (EPs) to attest to Meaningful Use for the Medicare EHR Incentive Program 2013 reporting year from Feb. 28, 2014 to 11:59 pm ET on March 31, 2014. This extension will allow additional time for EPs to submit Meaningful Use data and receive an incentive payment for the 2013 program year, as well as avoid the 2015 payment adjustment. Note that this extension does not impact the deadlines for the Medicaid EHR Incentive Program or any other CMS program, including electronic submission for the PQRS EHR Incentive Program Pilot.
CMS Registration and Attestation Tips:
Ensure payment assignment and other relevant information is up to date in the Medicare payment system (PECOS)
Include a valid email address in your EHR program registration
Access the attestation system during non-business hours
Enter 2013 attestation data early to identify potential problems well before the new deadline
Report any problems to the EHR Incentive Program Help Desk
If your organization has more than 1,000 providers assigned to a proxy user, use the PECOS system to designate additional proxies to facilitate attestation
On Feb. 10, MGMA, along with the AMA and other state and national specialty organizations, sent a letter to House and Senate leadership congratulating them on their significant progress towards advancing repeal of the Sustainable Growth Rate (SGR) formula. To show your support for finding a long-term solution, visit our advocacy center and tell your lawmaker to repeal the SGR now!
Further delay for ACA employer mandate
The Treasury Department issued new regulations and an accompanying fact sheet delaying full implementation of the Patient Protection and Affordable Care Act (ACA) provision stipulating that certain employers must provide health insurance or face fines. The employer responsibility provision will be phased in, applying to firms with 100 or more full-time employees starting in 2015 and to employers with 50 or more full-time employees starting in 2016. To avoid a penalty for failing to offer health coverage, employers need to offer coverage to 70% of full-time employees in 2015 and 95% in 2016 and beyond.
Congress advances SGR repeal legislation
Today the House Committees on Energy & Commerce and Ways & Means and the Senate Committee on Finance reached a bi-cameral, bi-partisan deal on legislation to repeal and replace the current Sustainable Growth Rate (SGR) formula. In addition to repealing the SGR, the proposed legislation provides for 0.5% annual fee schedule updates for five years during a transition period that integrates value-based programs into the Medicare physician payment system. There is still little information on how Congress might pay for the legislation, expected to cost in excess of $128 billion. The cost is the largest political and practical hurdle to passage of this bill. MGMA will continue to update members on any further SGR movement through the Washington Connection.
New MGMA ICD-10 research suggests industry coordination lagging
With less than eight months before the Oct. 1 compliance date to transition to ICD-10, MGMA research suggests that overall industry readiness for implementation continues to lag. The results, compiled through the Association's Legislative and Executive Advocacy Response Network (LEARN), indicate that less than 10 % of practices report making significant progress when rating their overall readiness for ICD-10 implementation, up only slightly (from 4.7%) since June 2013, when MGMA previously conducted LEARN research to assess readiness levels. The research also suggests that practice testing with software vendors, clearinghouses and health plans is significantly behind schedule. The new research includes responses from more than 570 medical groups where more than 21,000 physicians practice.
Learn about the future of Medicare payment at FMPC
Despite frustration over another short-term patch to the Sustainable Growth Rate (SGR) formula, there are promising signs that SGR repeal may be on the horizon. Three key congressional committees passed SGR repeal legislation in 2013, making 2014 ripe for continued discussion on how to replace this flawed Medicare payment system with value-based and alternative payment models. Gain a deeper understanding of new Medicare payment models that may impact medical practices in the coming years by attending the MGMA Government Affairs Update on Emerging Medicare Payment Models at the 2014 MGMA Financial Management and Payer Contracting Conference in Orlando, March 2 – 4.
Attendees will also learn more about the impact of other timely legislative and regulatory issues affecting group practices at the MGMA Government Affairs Update on Recent Developments and Hot Topics. This session will review a number of federal regulatory developments such as changes for 2014 to Medicare quality reporting programs (and how to avoid program penalties), compliance and new Medicare policies.
OIG releases 2014 work plan
The HHS Office of Inspector General (OIG) released its 2014 Work Plan, which provides brief descriptions of activities that the OIG plans to initiate or continue in fiscal year 2014. While the annual document is usually released in the fall, the OIG delayed its release to better align with priorities HHS has set for the year.
CMS announces interim results from Accountable Care Organizations
On Jan. 30, the Centers for Medicare & Medicaid Services (CMS) announced interim financial results for selected value-based payment initiatives including Pioneer ACOs, Medicare Shared Savings Program ACOs and the Bundled Payments for Care Improvement Initiative. The CMS press release noted that in their first 12 months, 54 out of 114 ACOs had lowered expenditures while only 29 lowered expenditures in amounts exceeding their benchmarks to generate shared savings.
HHS allows patients direct access to their lab results
The Department of Health and Human Services released a final rule amending the Clinical Laboratory Improvement Amendments of 1988 (CLIA) and Health Insurance Portability and Accountability Act of 1996 (HIPAA) regulations to allow patients to receive test results directly from laboratories. While some states currently allow patients to receive test results directly from a lab, the majority do not. The final rule will provide a national standard. MGMA submitted comments on this rule when it was proposed in 2011.
HHS releases HIT safety guides and interactive tools
The Department of Health and Human Services has released a new set of guidelines to help healthcare providers address safety issues relating to EHRs and other health information technology. The nine Safety Assurance Factors for EHR Resilience (SAFER) Guides are divided into three broad categories; foundational, infrastructure and clinical process. They were developed by the Office of the National Coordinator (ONC) with input from MGMA's Patient Safety and Quality Advisory Committee.
CMS extends current RAC contracts
With current contracts for the recovery audit contractors (RACs) set to expire in February, the Centers for Medicare & Medicaid Services (CMS) recently announced it will extend existing RAC contracts several months "through the awards and implementation phases of the new contracts." The new contracts will implement CMS's previously announced RAC restructure, which will include four regional RACs for Medicare Parts A and B services and one national RAC for durable medical equipment, home health and hospice services. As a result of the contract extension, MGMA members may continue to receive new correspondence from their existing RACs, including additional document requests, semi-automated notification letters and notices of automated review. CMS has indicated that healthcare providers will not be required to respond to requests from two different RACs simultaneously.
Visit MGMA's RAC resource center for more information on the RAC program and helpful tools, including the RAC Appeals Navigator, a member benefit that guides you through the RAC appeals process. If your practice has experience with a RAC audit, please consider sharing your experience with MGMA to assist in our advocacy efforts.
Last chance! Share your ICD-10 readiness with MGMA
Please take a few minutes to complete this brief questionnaire to share your practice's ICD-10 readiness level with MGMA. For many organizations, the ICD-10 transition on Oct. 1 will require practice management system and EHR software upgrades or replacement to accommodate the codes, clinical documentation modifications, and extensive training for clinicians and administrative staff.
As a continuation of the research MGMA conducted in June 2013, this research allows the association to more accurately track industry progress and will assist in critical member advocacy and education efforts. The survey takes only five-ten minutes to complete and participation is vital. Visit MGMA's ICD-10 resource center to find our ICD-10 preparation guide and other helpful resources and information.
MGMA/AMA checklist for 2014 ACA exchange implementation
Many issues with health insurance obtained through the Affordable Care Act (ACA) exchanges, including eligibility verification, present the same difficulties practices face with other commercial insurance. However, the new ACA exchange products also introduce some unique challenges that practices should be prepared to address. For example, practice staff need to know key effective dates for coverage based on when a patient enrolls. Coverage from ACA exchange plans began as early as Jan. 1, and the initial enrollment period remains open until Mar. 31. The effective date of coverage depends on when a patient enrolls; if a patient signs up on or before the 15th of the month, coverage begins on the first day of the following month. However, if a patient signs up after the 15th of the month, e.g., on Jan. 20, coverage begins a month later, e.g., March 1.
MGMA members can learn more about successfully managing challenges brought by ACA exchange implementation with this new checklist, or by accessing our ACA resource center. Please share feedback on interactions with ACA exchange plans by contacting the Government Affairs department via email, or by calling us at 202-293-3450.
As patients begin to visit practices using new health insurance obtained through the Affordable Care Act (ACA) exchanges, practices need to be prepared. MGMA, in partnership with the American Medical Association, created a checklist to help our members successfully manage the challenges brought by exchange implementation in 2014. For more information, visit our ACA resource center.
Feb. 28 is final day to contest 2014 eRx penalty
2014 is the final year a penalty will be applied in the Medicare e-prescribing program. The 2014 penalty is based on reporting from previous years; moving forward there will be no incentive opportunities available. Therefore, practices no longer need to report the G8553 code on claims to indicate an e-prescription took place.
Providers who do not believe they should be subject to the 2014 e-prescribing penalty may contest the penalty determination by requesting an informal review. Informal review requests must be submitted via email no later than Feb. 28, 2014. The request must include the individual rendering National Provider Identifier (NPI), contact information, (email, telephone, mailing address) and justification for requesting an informal review. Additional instructions for requesting an informal review are available here. For more information on e-prescribing, visit MGMA's resource center.
EFT and ERA operating rules now in effect
As of Jan. 1, health plans are required to provide practices payments via electronic funds transfer (EFT) using a national standard that incorporates new business conventions known as operating rules. In addition, health plans must support the new operating rules for electronic remittance advice (ERA). The new EFT standard and operating rules for both transactions were mandated under the Affordable Care Act (ACA). Health plans face significant fines if not compliant.
The ACA operating rules require health plans to:
Use a consistent format and form for EFT/ERA enrollment
Automate the re-association of EFTs and ERAs
Release EFT payments and ERAs in a reasonable timeframe
Provide instructions on how to fix late/missing EFTs and ERAs
Send "trace numbers" necessary for successful re-association
Utilize claim adjustment reason codes and remittance advice remark codes to convey details of common claim denials or payment adjustments
To help practice professionals transition to these new standards, MGMA has developed an EFT and ERA Guide, which includes a description of the standard and operating rules, automation benefits, and implementation steps. In addition, MGMA members can access a sample letter for requesting EFT payments from health plans. Find these and other resources at MGMA's administrative simplification resource center.
How will ICD-10 impact your practice? Tell MGMA!
MGMA is currently seeking member feedback to determine the readiness level of practices and their trading partners for the Oct. 1 ICD-10 compliance deadline. For many practices, the ICD-10 transition will require practice management system and EHR software upgrades or replacement to accommodate the codes, clinical documentation modifications, and extensive training for clinicians and administrative staff.
As a continuation of the LEARN research MGMA conducted in June 2013, this survey allows the association to more accurately track industry progress and will assist in our member advocacy and education efforts. Please take a few minutes to complete this brief questionnaire, your feedback is critical! For more ICD-10 information and resources, visit MGMA's resource center.
Final 2014 Medicare Physician Fee Schedule Analysis
Members, don't forget to download MGMA's detailed analysis of the 2014 Medicare physician fee schedule final rule. It explains important changes to Medicare physician payments and quality reporting programs for next year. Among other issues, the analysis covers:
Adjustments to the Geographic Practice Cost Indices (GPCIs) and the Medicare Economic Index (MEI)
Expanded Value-Based Payment Modifier policies
Changes to PQRS reporting criteria to both earn an incentive and avoid a 2016 penalty
Additions to the Physician Compare website
For a walk-through of the 2014 final fee schedule, members can also access our General Medicare Update for 2014 webinar, now available now available
January 8, 2014
Top 10 Issues to Watch for During the Legislative Session
1. Medicare payments remain in flux
On Dec. 26, 2013, President Obama signed into law the Pathway for SGR Reform Act of 2013 as part of the December budget agreement reached by Congress. This law includes a three month reprieve from the 20 percent plus cuts scheduled to take effect Jan. 1 due to the Sustainable Growth Rate (SGR) formula, while also extending the 1.0 work GPCI floor and therapy caps exceptions process during this time. With the temporary solution currently set to expire March 31, Congress will continue to consider options for repeal or delay of the SGR and its resulting cuts, which will likely spillover into larger deficit reduction efforts by Congress this spring.
Payment adjustments from the final 2014 Medicare physician fee schedule are also now in effect, including changes to RVUs and the conversion factor. MGMA created an analysis exclusively for members to help them understand the key changes to Medicare Part B for 2014.
2. SGR repeal and replacement
Three key congressional committees passed SGR repeal legislation in 2013, making 2014 ripe for continued discussion on how to replace this flawed payment system with value-based and alternative payment models. MGMA will continue its steadfast advocacy efforts for a full repeal of the SGR in 2014. For more information, visit MGMA's reimbursement page.
3. ACA implementation
This is a key year for implementation of the Affordable Care Act. Despite the bumpy rollout of healthcare.gov, insurance coverage offered through the ACA exchanges or marketplaces began Jan. 1. Meanwhile, many states are also expanding their Medicaid programs beginning in 2014. For more information on the continued implementation of the ACA, visit MGMA's resource center.
4. Countdown to ICD-10 transition
This year, practice professionals face the challenging task of preparing their organizational infrastructure and staff for the Oct. 1 ICD-10 compliance deadline. Critical issues that will need to be addressed include upgrading practice software, ensuring that patient encounters are appropriately documented, adequately training clinical and administrative staff, testing internally and with external trading partners, and establishing a contingency plan should there be any cash flow disruption. MGMA is currently seeking feedback from members regarding ICD-10 implementation through our LEARN survey. Please take a moment to fill out this brief questionnaire that will assist MGMA in providing feedback to policymakers. Members are also encouraged to utilize the ICD-10 resources available at our resource center.
5. Expansion of Value-Based Payment Modifier
The 2014 Medicare physician fee schedule includes a vast expansion of the Value-Based Payment Modifier (VBPM) program. The 2016 VBPM will impact group practices with 10 or more eligible professionals based on 2014 performance, making this year a critical one for physician group practices to avoid penalties associated with this complex program. Access MGMA's federal quality reporting programs resource center for more information on the VBPM and how to prepare your practice for 2016.
6. Stage 2 Meaningful Use begins
The second stage of the Medicare and Medicaid EHR Incentive Program (Meaningful Use) began Jan. 1, 2014. While the government recently extended the start date of Stage 3 to 2017, eligible professionals (EPs) are still required to attest to meeting the 2014 criteria to avoid future Medicare payment adjustments. EPs are expected to face a difficult task with the more demanding Stage 2 requirements, including having a minimum of five percent of patients utilize the practice's online portal to view, download, or transmit their medical record. Practice professionals are encouraged to review software options with their vendors and access resources at MGMA's Meaningful Use webpage.
7. Quality reporting program penalties continue
2014 will serve as the performance year for multiple federal quality reporting program penalties scheduled to take effect in 2016. These programs (Physician Quality Reporting System, VBPM, and Meaningful Use) continue to grow in complexity, while penalties continue to increase each year. Physician group practices will need to report quality measures for each of these programs in 2014 to avoid 2016 penalties that, in total, can amount to up to negative six percent of Part B covered professional services under the Medicare physician fee schedule. Visit our quality reporting resource center and read our 2014 Medicare Physician Fee Schedule Analysis to learn how to avoid these costly penalties.
8. Administrative simplification
Augmenting the existing HIPAA administrative simplification requirements, the Affordable Care Act included a number of new initiatives, including several taking effect in 2014. As of Jan. 1, 2014, health plans are required to offer practices the option of accepting electronic funds transfer (EFT) payments using new standards and operating rules. In addition, health plans are required to offer newly standardized electronic remittance advice (ERA). Moving to EFT and ERA will automate an important component of the claims revenue cycle and could provide a significant return on investment. Practice professionals should discuss these and other administrative simplification opportunities with their software vendors. Additional information is available at MGMA's HIPAA resource center.
9. Heightened emphasis on compliance
With last year's release of augmented HIPAA requirements, it is anticipated that the government will expand its privacy and security enforcement efforts. In addition, government and patient scrutiny of HIPAA security breaches will likely escalate. MGMA members should understand the steps they need to take to protect their practices. CMS remains focused on its efforts to reduce fraud, waste and abuse in the Medicare and Medicaid programs. Practices will continue to hear from government auditors in 2014 as we await several other compliance-related rules, including a final rule addressing the requirement to report and return overpayments within 60 days. Beginning Jan. 6, new requirements are in place for physicians who order and refer Medicare services aimed at protecting the integrity of the Medicare program. Members seeking more information on these topics should visit MGMA's HIPAA and compliance resource centers.
10. Physician information goes live on new website
2014 is the first year information about physicians' relationships with drug and device manufacturers and group purchasing organizations (GPOs) will be made public. CMS will soon allow physicians to register with its Open Payments system in order to review and correct information reported about them by drug and device manufacturers and GPOs before it is made public in September. Information will be available for review beginning in June. For more information on the Open Payments program, listen to our member-benefit webinar, read our "what you need to know" member resource and visit our webpage dedicated to the program.