By Jim Tate, EMR Advocate
Meaningful Use Audit Expert
Twitter: @JimTate, eMail: Inquiry@meaningfuluseaudits.com
The initial notifications of Centers for Medicare & Medicaid Services (CMS) meaningful use (MU) penalties shocked many a health care provider. Years of incentive programs were initiated to stimulate the adoption and use of electronic health records, and many providers did not realize there was a backside to the incentives – penalties.
The full range of providers, from solo practitioners to large hospital systems, are now within the scope of the in-coming wave of penalties.
For Medicare Subsection (d) eligible hospitals that failed to become “meaningful users of certified technology” by October 1, 2014, the penalty will slash their Inpatient Prospective Payment System. As a direct result, critical access hospitals will experience a reduction to their “reasonable costs” payments.
That said, the largest potential smack down is reserved for the hundreds of thousands of providers in clinics and private practices. More than 250,000 eligible professionals were notified they would be penalized as of January 1, 2015 for not becoming meaningful users.
Here’s what is in store for this unsuspecting lot:
MU: Failing to achieve MU in 2014 will bring a 2% penalty beginning in 2016 with a 1% annual increase up to 5%.
Physician Quality Reporting System (PQRS): Non-participation brings a Medicare reimbursement reduction of 2.0% in 2016 based on 2014 data.
Value-Based Modifier(VBM): The VBM, which many providers are not aware of, is linked to PQRS. Beginning in 2016, eligible providers (EPs) in groups with 10 or more EPs will be subject to a penalty based on performance. In 2017, this will include all EPs, not just those in larger groups.
Taken together, this adds up to a 9% penalty in 2017 based on 2015 participation.
To avoid these penalties, immediately assess your current participation in the MU, PQRS, and VBM programs. If you are not on track you must take steps to mitigate your risk as soon as possible.
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: audits@emradvocate.com.