Latest News

Time is running out for MIPS Improvement Activities!

Posted by on Sep 20, 2017 in Latest News | Comments Off on Time is running out for MIPS Improvement Activities!

Time is running out for MIPS Improvement Activities!

If you’re an individual or group planning to participate in the new Improvement Activities (IA) category of MIPS, you should be aware that you must begin engaging in your chosen activities by no later than Oct. 2 in order to complete the requirement that your activities be completed over a 90-day period in 2017. While non-patient facing (NPF) and small physician groups face a lower reporting burden than regular participants, the IA category still counts for 15 percent of your overall MIPS score, regardless of the number of activities you’re required to complete. As a refresher, activities are weighted either as high or medium depending on their administrative burden. A patient-facing group must complete some combination of the following: two high-weighted, four medium-weighted, or one high and two medium-weighted. Meanwhile, NPF and groups of 15 or fewer providers must only complete either one high-weighted or two medium-weighted activities to earn the full 40 points available for the category. If you’re unsure whether or not your group qualifies for special status under MIPS, you can check by entering your NPI at qpp.cms.gov. CMS has approved a list of 93 activities for 2017. If you’re unsure which activities would work best for your group, take time to review the whole list to check whether you’re already engaging in an improvement activity. Vachette has also assisted numerous clients through this process and is available to make recommendations on activities that would best suit your practice. While you won’t be required to report anything to CMS during the 90 days you’re completing the activity, you will be expected to sign an attestation form stating you completed the activity when CMS opens the attestation portal sometime in early 2018. This form will simply require you to complete a survey with questions pertaining to your chosen activity. You’re not required to submit documentation proving you completed your activities, however, you should still be documenting completion of the activity in the rare event CMS elected to audit your MIPS performance. One activity that we’ve recommended for several pathology clients is a high-weighted activity titled “24/7 Access to the MIPS Eligible Clinician With Access to Patient Records.” Since the vast majority of pathologists already have someone from their group available 24/7, this is a relatively simple choice. To document this activity, groups should be maintaining a shift log showing who from the group was available on what days during the extended evening and weekend hours. Additionally, patient-care activities performed during these hours should also be documented. This could include items such as a blood smear interpretation signed out of your EMR, or a surgical pathology report that was signed electronically during normal business hours a day or two after the “after hours” event, but includes documentation of an after-hours frozen section evaluation that was part of the case. Regardless of which activities you choose, now is the time to get moving if you haven’t already. If you’re a group just looking to avoid the 2019 MIPS penalty, completing just a single improvement activity this year will help you achieve that goal. Don’t wait until it’s too late to...

Read More

Avoiding scrutiny under the new CMS audit process

Posted by on Sep 5, 2017 in Case Studies, Latest News | Comments Off on Avoiding scrutiny under the new CMS audit process

With CMS recently announcing the agency is directing its Medicare Administrative Contractors to focus their audits and claim reviews on providers with consistently high error rates, it’s important to understand specifically what shortcomings could put your claims process under the microscope. CMS has said the goal of this new initiative, dubbed the Targeted Probe and Educate Pilot, is to prevent fraud, avoid unnecessary payments and to be less of a burden on providers whose billing operations are running smoothly. Select MACs will be asked to choose claims for services that carry a significant financial burden for Medicare, in addition to those that produce consistently high error rates. The good news is that unlike the old review system, which included all providers for a designated service during the initial round, providers who are already submitting claims with low error rates will be exempted from the review process. Unfortunately, while this new process will reward compliant health systems with less oversight, those who are found to be consistently falling short of CMS’s standard will need to show substantial improvement between reviews to avoid penalties. Those who are determined to still have an undesirable error rate after three rounds of review could face actions such as referral to a recovery auditor or 100 percent pre-pay review. Providers must display an ability to reduce their claims error rate between rounds of review in order to be removed from the cycle. So what does this mean for the average group? For starters, it’s more important to ensure your billing staff is informed of this change and is working with you to minimize coding errors. Even small mistakes could put you under the crosshairs of the new process. In one recent example, our audit team reviewed a caseload where  we found 2 percent of cases reviewed had a coding error that caused prostate TURP to be billed as G0416 to Medicare after the biller’s system mistakenly updated 88305 to G0416! Repeated mistakes like these are what MACs will be looking to identify. If you have any concerns about your claims process, now may be the time to consider preemptively bringing in a third-party auditor to review your work before the government comes calling. Vachette has worked with hundreds of clients throughout the nation and has the ability and expertise to identify and correct problem areas in your billing...

Read More

Highlights of the 2018 MIPS Proposed Rule

Posted by on Jul 15, 2017 in Latest News | Comments Off on Highlights of the 2018 MIPS Proposed Rule

Highlights of the 2018 MIPS Proposed Rule

While many clinicians are still working to get a handle on the requirements for the Merit-based Incentive Payment System, they also need to keep an eye on how the program is expected to evolve next year now that CMS has released its 2018 Quality Payment Program Proposed Rule. However, those fearing the bar for penalty avoidance would be raised to unreasonable heights should breathe easy knowing CMS won’t require much more from you than what they asked for in 2017. With that in mind, here are six of the most significant changes:   1)    Significant increase of the low-volume thresholds CMS has proposed to raise the low-volume MIPS exemption thresholds to $90,000 in annual Medicare payments or services to 200 or fewer Medicare beneficiaries, a significant increase from the $30,000 or 100 patient thresholds for 2017. Falling below either one of these thresholds as an individual clinician will exempt you from participation, which means those who were barely over this year’s mark will most likely be exempt from the program next year. Keep in mind, however, that the increased threshold is also applied at the group level if your group elects to report collectively.   2)    No requirements for the “Cost” category While participants had originally been told to anticipate the introduction of a “Cost” category based on the old value modifier in 2018, CMS is now proposing to again give no weight to the fourth MIPS category next year. That being said, the agency is still soliciting feedback on whether Cost should be weighted at 10 percent of the total MIPS score for 2018, given that CMS still intends to count it as 30 percent of a participant’s score in 2019. Regardless, CMS says it intends to track Cost progress in 2018 based on Medicare Spending per Beneficiary and total per capita cost measures. They’re also working to develop a handful of episode-based cost measures.   3)    Slight threshold increase for penalty avoidance Clinicians who were happy with the extremely low bar set by CMS this year to avoid a Medicare penalty in the 2019 payment year should find relief in learning they won’t be asked to do much more next year to avoid a 2020 penalty. While the 2017 performance threshold of 3 (the total MIPS score required to receive a neutral adjustment) was able to be achieved by essentially submitting any quality data or completing at least one improvement activity, the 2018 threshold will be raised to just 15 points. This can be achieved in a variety of ways, including by submitting complete data for just two quality measurements or completing the full requirements of the improvement activities category. Non-patient facing clinicians, hospital-based groups and groups consisting of 15 or fewer members will still only be required to complete either one high-weighted or two medium-weighted activities to get the full score.   4)   Automatic bonuses for small and rural practices Given the reporting hurdles faced by small (15 clinicians or fewer) and rural practices, CMS is proposing to award an automatic five points to these clinicians scores next year. This is likely to be locked in for small practices, however, CMS is still seeking comment on whether rural practices should receive the same benefit.   5)    New facility-based scoring mechanism No concessions for facility-based clinicians was made in 2017, but CMS is looking for change that for next year. In addition to the traditional MIPS route, the agency will implement a voluntary facility-based scoring system based on the Hospital Value Based Purchasing Program. This format will be available to clinicians who have at least 75 percent of their covered professional services...

Read More

Republicans weighing AHCA amendment

Posted by on Apr 6, 2017 in Latest News | Comments Off on Republicans weighing AHCA amendment

Republicans weighing AHCA amendment

Throughout Donald Trump’s presidential campaign, promises were made and a clear line was drawn in the sand indicating that if he was elected the Affordable Care Act (ACA) would be repealed and replaced.  In March the GOP took its first swing during Trump’s presidency at replacing the ACA with the American Health Care Act (AHCA). Health care experts on both conservative and liberal sides of the political spectrum described this attempt at reform as a failure right out of the gate due its inability to lower deductibles, offer affordable and comprehensive coverage to the middle class and the potential changes it could bring to Medicaid. On Thursday, House Speaker Paul Ryan revealed an amendment to the AHCA that would establish a federal risk sharing program for insurers, an idea that has received support from both moderate and conservative Republicans. The revised act would aim to lower premiums and increase the total number of insurers who offer plans, which Republicans in turn hope would create a competitive marketplace with more choices for consumers. Currently, many consumers are left with limited choices in the marketplace after a recent exodus by many carriers. According to Ryan, the amendment maintains the ACA mandate to provide coverage to those with pre-existing conditions while also providing states with more options. The “high-risk sharing” pool would be used to reimburse insurers for covering patients with expensive conditions, which Republicans hope would in turn lead to lower premiums across the board. The pool would be administered by the federal government for three years before being handed over to the state level. Freedom Caucus members, Republicans of the most conservative and libertarian nature, were not convinced that the initial AHCA effectively abolished some of the more troublesome elements of the ACA. With Freedom Caucus members essentially voting against their party, it was decided that the AHCA would be withdrawn and no vote would take place. It will be interesting to see how those members respond to this latest proposal. Ryan said he believes the gap between his party’s two sides is narrowing, but that will remain speculation until the bill is actually voted on, let alone passed. After the AHCA vote was initially pulled, Ryan stated that the country is, “going to be living with Obamacare for the foreseeable future,” putting doubt in the minds of all citizens in regards to the GOP’s ability to craft a successful (and popular) replacement. Now, it’s looking like Republicans may be able to stop their infighting long enough to turn one of Trump’s early failures into a potential win. By Jake Hoogendoorn, Marketing...

Read More

Can your biller help you successfully navigate MIPS?

Posted by on Feb 24, 2017 in Latest News | Comments Off on Can your biller help you successfully navigate MIPS?

With the inaugural reporting period for CMS’s new Merit-based Incentive Payment System now underway, you should be preparing a plan for how you’ll fulfill the program’s requirements, which can vary greatly depending on several factors ranging from the size of your practice to the number of patients you deal with directly each year. In recent years, many groups have relied on their billers to assist with reporting quality metrics required by the Physician Quality Reporting System. However, we’ve encountered numerous groups who have suffered Medicare penalties due to their biller’s failure to properly submit all the claims data required by PQRS. The reality is that although billers have good intentions, they often cannot keep up with the constant changes to these programs put forth by CMS. This has progressed to the point that many billers have now said they will either no longer assist with quality reporting or are charging additional fees to continue doing so. With that in mind, here are 22 items to consider as you prepare for MIPS: Are you confidant your biller truly understands the intricacies of the four MIPS performance categories: Quality, Practice Improvement, Advancing Care Information and Cost? Does your biller understand how those categories relate to the Physician Quality Reporting System (PQRS), Value Modifier (VM) and Electronic Health Record Meaningful Use (EHR MU) programs? Have you and your biller examined your Medicare payment history to determine whether or not you’re required to report under MIPS? Were you aware that CMS has dubbed 2017 as a “transition” year for MIPS? Have you and your biller had a conversation about what this entails, and what future years of the program could look like? Do you know whether you qualify for a MIPS exemption because of your hospital’s participation in a CMS-approved alternative payment model (APM)? Aware you aware of the potential benefits, as well as the risks, of participating in these various APMs? Have you received PQRS or Value Modifier penalties in the past? Was your biller able to explain why you came up short? If you did receive Medicare penalties under previous programs, did your biller offer to assist you with the appeal process? Was the appeal successful? Are you aware of whether you meet CMS’s designation as a non-patient facing clinician under MIPS? You should understand both the threshold for this designation and its potential impact on the categories you’ll be required to report on. Do you understand the differences between quality reporting under PQRS and the new Quality category of MIPS? How intimately does your biller understand the various quality measure groups of the Quality category? Can they help you determine which measures are applicable to your group, and how many you must report on to achieve your full score? Does your biller know the MIPS scoring thresholds that could open your group to receive additional Medicare bonuses beyond the maximum 4 percent initially offered for 2019? Has your biller determined whether or not your group will be required to report in the Advancing Care Information category? Do they understand how a category’s weight is redistributed if you receive an exemption? Have they discussed what Practice Improvement activities among the more than 90 available options would best suit your group. Have they supplied you with a plan for how to best fulfill the category’s requirements? Do you understand what you must do to attest you’ve completed your Practice Improvement activities? Were you aware the Cost category won’t count toward your total MIPS score in 2017, but will be in play for the 2018 reporting year? Has your biller informed you that...

Read More

Understanding the benefits of registry reporting

Posted by on Jan 20, 2017 in Latest News | Comments Off on Understanding the benefits of registry reporting

Understanding Registries With the first reporting period for the Merit-based Incentive Payment System now underway, you’re probably already spent some time considering how you’ll report your quality data (and if you haven’t, now’s the time to start)! Most groups fulfilled their PQRS requirements in the past by submitting data through the routine Medicare claims process, however, that process has become more burdensome in recent years and can leave you with uncertainties over whether you’ve reported all the applicable data required. What is a reporting registry? The registries referred to in this article were created to assist physicians in reporting quality data to CMS as part of the old Physician Quality Reporting System. Instead of placing the entire reporting burden on an individual group or practice, registries allow groups to submit their data to a third-party vendor that can scrub the submission to ensure it’s as accurate as possible before being sent off to CMS. This process aims to provide users with feedback that can help them fix their reporting processes during a submission period as opposed to waiting more than a year and a half for CMS to provide feedback on your data. Why use a registry? Working with a registry greatly reduces the burden on your billing and reporting staff. The registry staff can provide guidance with compiling necessary data. The registry can send in test submissions, which in turn allow them to minimize issues during the actual submission period. What’s the cost? Typically around $300 per physician. How are they approved by CMS? In order for an entity to be considered a qualified registry, the registry must successfully complete the self-nomination process and follow requirements outlined by CMS each year. Individual physicians or group practices who wish to report via registry should review the 2017 Qualified Registries once it is released this spring to find a registry that best meets the practice’s needs, since the vendor may only support specific measures or reporting options. (Click here to view the 2016 list of approved registries.) Who is able to report through a qualified registry? For the initial 2017 MIPS reporting year, both individuals and group practices can report through a qualified registry. Unlike past years, those wishing to report as a group will not need to complete the Group Practice Reporting Option registration in order to be recognized as a reporting group. Instead, those groups will now be able to self-nominate as a group through their registry. This is also the first year that groups will be prevented from submitting their quality data through the Medicare claims...

Read More