From the
PRESIDENT
ROBERT “BOB” H. COUCH, MD, MBA
GLMS President | [email protected]
To listen to Dr. Couch’s article as a podcast or watch
the video, visit our link on www.glms.org.
CARROT OR STICK?
S
cripture tells us that the Lord giveth and
the Lord taketh away. We can apply that
view to the Centers for Medicare and
Medicaid Services, CMS, the entity responsible for paying close to a trillion dollars for
health care in this country in 2015. We are
often offered incentives to change our performance in the fashion of the carrot or the stick.
One such “incentive” is the Physicians Quality Reporting System, PQRS. It provided incentive payments for reporting quality data for
Medicare patients. The Affordable Care Act
modified the system and changed the bonus
to a penalty. Beginning with reimbursements
during 2015, physicians could see a significant
reduction in overall Medicare payments if
PQRS measures are not met.
PQRS has hundreds of measures, including cost-cutting measures such as age cutoffs
for cancer screening procedures. Until now,
participation was voluntary, with a payment
adjustment for successful participation. The
payment adjustment remains, but it now eliminates any bonus payments and only provides
for a downward adjustment in Medicare reimbursement. This year, the negative payment
adjustment is two percent based on participation in 2014. The program will continue
with a two year offset, meaning that failure
to participate successfully this year will negatively affect 2018 reimbursements.
A more disturbing trend involves meaningful use incentive payments. This program
came about in 2009 to provide incentive payments to eligible professionals and hospitals
that demonstrate meaningful use of electronic
health records. The goals were lofty and included the desire to better clinical outcomes,
improve population health outcomes, increase
transparency and efficiency, empower individuals and make research data on health systems
more robust. We are still waiting to see if these
goals are met.
Meaningful use incentive payments began
in 2011, and a physician who began participating in the Medicare meaningful use pro-
gram in that year could have received a total
of $44,000 over five consecutive years. An
eligible physician participating in the Medicaid meaningful use program could receive
$21,250 for participation in the first year,
and an additional $8,500 for each additional
year, up to five years. The maximum Medicaid
meaningful use incentive payment is a total of
$63,750 over six years. This sounds like a great
program, but it comes with a forewarning.
CMS giveth, and CMS taketh away.
man Services Office of Civil Rights. Failure to
provide documentation to support attestation
could trigger the Office of Inspector General
to investigate under the False Claims Act. It’s
all very frightening.
The latest threat to physician payment is
the meaningful use audit. Did you think the
money CMS paid out had no strings attached?
CMS contracted with the accounting firm
of Figliozzi and Company to send letters to
physicians requesting documentation that
recipients of meaningful use payments have
the documentation to support their attestation
that meaningful use requirements were met.
Providers can be audited by CMS for up to
six years following attestation, so it’s important to retain documentation for that long.
According to some reports, the auditors are
requesting four types of data: documentation
from the Office of the National Coordinator
for Health IT showing that the provider used
a certified EHR system for meaningful use
attestation; information about the method
used to report emergency department admissions; documentation that the provider
has completed attestation for the core set of
meaningful use criteria; and documentation
that the provider has completed attestation for
the required number of menu-set meaningful
use objectives.
Medicare recovery audits have been around
for quite some time. In fiscal year 2014, recovery auditors identified more than a million
health care claims for improper payments that
resulted in almost $2.4 billion in overpayments
returned and $173 million in underpayments
repaid to provide