December 11, 2013
SGR repeal efforts heat up in Congress
MGMA calls on CMS to expand ICD-10 Testing
- Quickly disseminate the results of all Medicare testing;
- Expedite the release of Local Coverage Determinations and all other Medicare claim transaction edits associated with ICD-10;
- Publically release the ICD-10 readiness levels of all MACs and state Medicaid agencies on a monthly basis; and
- Develop a policy of advance payments for all Medicare or Medicaid providers that request them.
New Meaningful Use timeline and certification standards
Leading industry group issues 2013 HIT roadmap
December 8, 2013
MGMA-AMA Medicare ordering/referring fact sheet newly updated to reflect Jan. 6 changes
As previously announced, on Jan. 6, the Centers for Medicare & Medicaid Services will begin denying claims of providers who furnish services not meeting the agency’s ordering and referring criteria. For claims to be processed successfully, ordering/referring providers must be eligible to order or refer in Medicare, their legal name and NPI must be listed on the claim, and they must have an enrollment record in Medicare.
It is important for practices to understand the CMS criteria and to look for warnings currently being issued to avoid future denials. CMS has been issuing the following Claim Adjustment Reason Codes on remittance advice that face denial on or after Jan. 6:
- N264: Missing/incomplete/invalid ordering physician provider name
- N265: Missing/incomplete/invalid ordering physician primary identifier
MGMA successfully sought and received a three-year delay in implementation of this policy. Our ordering/referring fact sheet, co-authored with the American Medical Association, outlines key issues practices need to know to avoid claim denials. The fact sheet has now been updated to reflect the changes effective Jan. 6. More information on enrollment is available on MGMA’s enrollment page.
Meaningful Use: Top member questions
As 2014 approaches, MGMA members are focused on meeting the Stage 2 challenges of Medicare’s EHR Meaningful Use incentive program. The MGMA Government Affairs staff receives a wide range of questions from members at all stages of meaningful use participation; from those planning to demonstrate Meaningful Use for the first time in 2014 to those participating in the program for several years. In order to help you successfully demonstrate Meaningful Use in 2014 and avoid looming penalties, we have compiled a list of answers to the most common questions your colleagues are currently asking. For additional information on meaningful use, visit MGMA’s Meaningful Use resource center.
Senate Finance Committee to hold SGR repeal markup
On Dec. 12 the Senate Finance Committee will hold a markup expected to include a repeal of the Sustainable Growth Rate (SGR) formula. Last month the committee, in conjunction with the House Ways and Means Committee, released a draft legislative framework that would eliminate the SGR, reform the fee-for-service payment system with greater focus on value over volume, and encourage participation in alternative payment models. The committees did not suggest offsets to pay for the draft framework, expected to cost in excess of $140 billion. The high price tag remains the largest political hurdle to passing any SGR repeal legislation. MGMA will continue to update members on the status of this legislation as well as the impending cuts resulting from the SGR scheduled to begin Jan. 1. In addition to SGR cuts, physicians will again be faced with a 2% sequester cut in 2014 unless Congress intervenes. Contact your lawmaker today and urge them to repeal these cuts!
Log on to 2013 PQRS dashboard to access first quarter claims-based data
Eligible professionals (EPs) participating in the Physician Quality Reporting System (PQRS), as well as authorized users who reported using claims, may access their first quarter 2013 PQRS data by logging onto the 2013 interim feedback dashboard.
The dashboard allows EPs to monitor the status of claims-based individual measures and measures groups reporting for Jan-April 2013; it does not provide final data for full-year reporting or indicate 2013 PQRS incentive eligibility or 2015 penalty information. According to the Centers for Medicare & Medicaid Services (CMS) data submitted for 2013 PQRS reporting via methods other than claims will be available for review in the fall of 2014 through the final PQRS feedback report. For more information on how to access and interpret dashboard data, visit CMS’ user guide.
2014 Medicare participation status extension
The 2014 Annual Participation Enrollment provides eligible physicians, practitioners, and suppliers an opportunity to change their participation status with Medicare. Due to the delayed release of the 2014 Medicare Physician Fee Schedule Final Rule, the Centers for Medicare & Medicaid Services is extending the enrollment period through Jan. 31, 2014. The effective date for any participation status changes remains Jan. 1, 2014.
November 19, 2013
MGMA submits comments in response to draft SGR repeal framework
On Nov. 12, MGMA submitted comments to the Senate Finance and House Ways and Means Committees in response to their proposed legislative framework to repeal the Sustainable Growth Rate (SGR) formula. While the framework is a significant step in the right direction, MGMA has recommended several enhancements to refine the committees’ policy outline. Three priority areas of concern, among others, detailed in the comments include:
- Rather than freezing payment rates for a decade, a new Medicare physician payment system should adequately reimburse group practices for annual increases in the basic cost of providing patient care. This will provide a solid transitional foundation to implement new value-based payment mechanisms.
- Instead of housing Medicare quality programs under a single umbrella, new legislation should first address existing redundancies across the three Medicare quality reporting programs and create a single, unified approach to reporting. Measures should be reported once for all programs using a single method; not three separate times for each individual program, as is currently common.
- Under any new value-based payment system, Congress needs to not merely adopt, but improve existing Medicare quality programs. Current programs require significant methodological enhancements to address critical issues including attribution and risk adjustment.
If Congress does not act, Medicare physicians face a 24.4 percent SGR cut in 2014. Contact
your member of Congress today and urge them to support a full repeal of Medicare's flawed SGR formula this year.
Important Medicare ordering/referring and revalidation updates announced
The Centers for Medicare & Medicaid Services (CMS) released an updated educational article
announcing that it will move into Phase 2 of the ordering/referring edits Jan. 6. As previously reported
, Phase 2 will implement claims denials for providers who furnish services based on orders/referrals that do not meet the criteria. The requirements apply to ordered/referred items and services including DMEPOS, clinical laboratory and imaging services, and home health claims billed by Medicare Part B suppliers. For these claims, ordering/referring providers must be eligible to order or refer in Medicare, their legal name and NPI must be listed on the claim, and they must have an enrollment record in Medicare. Edits were originally scheduled to go into effect in 2010, but through our advocacy efforts MGMA successfully achieved a three year delay. The updated article also contains additional clarifying information about the process.
CMS also released a new educational article
on the next phase of Medicare revalidation
, which will last from Oct. 2013 through the spring of 2015. This phase will require all remaining organizations and individuals who enrolled or revalidated prior to March 25, 2011 to review their Medicare enrollment information and confirm its accuracy or make necessary changes. Medicare Administrative Contractors (MACs) will mail a notification letter
to group practices with 200 or more physicians who reassign their Medicare billing rights to the group to alert them that the MAC will send revalidation requests for specific physicians within 60 days.
PQRS informal review request period now open
As a reminder, CMS feedback reports are available for individual eligible professionals (EPs) and groups who participated in 2012 PQRS Group Practice Reporting Option. For more information on locating and interpreting data provided in the feedback report, review the 2012 PQRS Feedback Report User Guide
An informal review may be requested if the feedback report reveals that an EP or group practice did not earn the 2012 PQRS incentive payment when they believe they should have, or if they believe the payment amount was incorrect. Informal review requests will be accepted through Feb. 28, 2014. For more information about the informal review, see the 2012 PQRS Informal Review Made Simple
October 31, 2013
Key Congressional committees release draft SGR repeal legislation
The House Ways and Means and Senate Finance Committees today released a draft legislative proposal to eliminate the Medicare Sustainable Growth Rate (SGR) formula. The proposal would permanently repeal the SGR update mechanism, reform the fee-for-service (FFS) payment system through greater focus on value over volume, and encourage participation in alternative payment models (APMs). The revised FFS system would freeze current payment levels through a ten-year budget window, while allowing individual physicians and other health care professionals to earn performance-based incentive payments through a compulsory budget-neutral program. Beyond 2023, professionals participating in advanced APMs would receive annual updates of two percent, while all other professionals would receive annual updates of one percent.
MGMA will continue to provide input to the Congressional Committees on their SGR repeal efforts. The committees did not suggest offsets to pay for the draft bill, expected to cost in excess of $140 billion. The high price tag remains the legislation’s largest political hurdle.
HHS publishes top ten HIPAA security "myths
The Department of Health and Human Services recently released a list of “myths”
regarding the issue of security risk analysis. These risk analyses are mandated under the 2005 HIPAA Security final rule and are required in order for eligible professionals (EPs) to successfully attest under the Medicare and Medicaid Meaningful Use EHR Incentive Programs. CMS has indicated that failure to complete and document a security risk analysis is one of the leading factors for EPs failing a meaningful use audit.
CMS postpones release of 2014 Medicare payment rules
Due to the recent government shutdown, the Centers for Medicare & Medicaid Services (CMS) announced
that publication of the 2014 final Medicare physician fee schedule rule could be delayed until Nov. 27. The agency has stated that the rule will generally still be effective on Jan. 1, 2014. This announcement also applies to the hospital outpatient, ambulatory surgical center, and home health prospective payment system final rules. The practical implication of the delay in publishing the final rules is that medical group practices, as well as CMS contractors, will have less time to prepare for the policy changes than is typically the case.
As soon as the final physician fee schedule rule is released, MGMA will begin to analyze the regulation’s impact on medical group practices and will post our annual analysis online as a member benefit. Look for updates in the Washington Connexion.
View our 2014 Proposed Medicare Physician Fee Schedule Analysis
and other member-exclusive resources at MGMA's Medicare Physician Reimbursement Page.
Novitas Operational Difficulties
This is an update to the information regarding Novitas’ temporary operational difficulties. In an effort to keep you informed of those difficulties and what resolutions are complete/in progress you will continue to receive this type of notice regularly for a short while. The attachment includes information on some of those difficulties, where we are in resolving them and what issues have been resolved. This information can also be found on the Novitas Website in the “Pardon Our Dust – Site Under Construction” alert at the top of the screen via this hyperlink: View the Latest Updates on Issues and Enhancements.
October 24, 2013
Although we are still assessing the impact of the partial government shutdown on completion of the calendar year 2014 Medicare fee for service payment regulations, we intend to issue the final rules on or before November 27, 2013, generally to be effective on January 1, 2014. The impacted regulations include:
- Medicare Program; End-Stage Renal Disease Prospective Payment System, Quality Incentive Program, and Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (CMS-1526-F)
- CY 2014 Changes to the Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System (CMS-1601-FC)
- CY 2014 Home Health Prospective Payment System Final Rule (CMS-1450-F)
- Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2014 Final Rule with Comment Period (CMS-1600-FC)
October 23, 2013
MGMA advocates on Medicare date of service policy
MGMA, along with several other specialty associations, has been working with the Centers for Medicare & Medicaid Services (CMS) to address the date-of-service (DOS) policy for services that have both a professional component and a technical component. This policy largely affects diagnostic imaging services and pathology services.
CMS does not yet have a national policy addressing DOS. While the current industry practice is to use the DOS of the technical component as the DOS for both components, Medicare Administrative Contractors (MACs) can elect to use their own policies. Several MACs, including Wisconsin Physician Services and Novitas Solutions, have adopted policies that require the DOS for the professional component to be the date the professional service was actually performed.
MGMA recently sent a letter to officials at CMS outlining concerns with the MACs' policies. Our work with the agency on this issue has been ongoing for several years as CMS has considered various national policy options. We will continue to advocate on this issue and keep members informed of any developments.