The Medicare Physician Fee Schedule (MPFS) was updated using the Sustainable Growth Rate (SGR) Methodology as required by law. Beginning April 1, 2015, the SGR methodology required a 21% decrease in MPFS payments.
CMS took steps to limit the impact on Medicare providers and beneficiaries by holding claims paid under the MPFS with dates of services on and after April 1, 2015. Medicare is also holding therapy claims that no longer qualify for the therapy cap exceptions due to the expiration of the therapy cap exceptions process on April 1, 2015. In an effort to avert the negative update, “CMS must update payment systems to comply with the law, and implement the negative update.”
“Beginning on April 15th, 2015, CMS will release held MPFS claims, paying at the reduced rate, based on the negative update, on a first-in, first-out basis, while continuing to hold new claims as they are received. CMS will release one day’s worth of held claims, processing and paying at the rate that reflects the negative update. At the same time, CMS will hold the receipts for that day, thus, continuing to hold 10 days’ worth of claims in total. This is to provide continuing cash flow to providers, albeit at the rate that reflects the negative update. This “rolling hold” will help minimize the number of claims requiring reprocessing should Congress pass legislation changing the negative update.”
Please be aware that claims for services furnished on or before March 31, 2015 are not affected by the payment cut and will still be processed and paid under normal time frames.
Earlier this month, CMS held a Special Open Door Forum for the voluntary electronic and paper clinical template for the home health Face-to-Face (F2F) encounter document. During this call, a presenter provided inaccurate information regarding what would be acceptable documentation within the physician’s medical record to support home health eligibility.
Several participants questioned the presenters about the CMS policy that allows a physician to sign information from an agency’s assessment and incorporate it into his or her medical record to support eligibility. CMS answered by comparing agency documentation to consultation notes that may be found in a physician’s record, saying that CMS does not actually consider these documents to be a part of the physician’s record, since they are not generated by that physician. CMS indicated it would only look for documentation the physician generated to support home health eligibility. However, this interpretation goes against what CMS has spelled out in the final rule for home health prospective payment system (HHPPS) rate update.
NAHC contacted CMS requesting clarification of this matter. On March 24, CMS released the following statement:
“In reviewing the transcript, CMS realizes that inaccurate information was provided related to HHA documentation to support certification for home health services. Per 42CFR 424.22 (a) and (c), the patient’s medical record must support the certification of eligibility and documentation in the patient’s medical record shall be used as a basis for certification of home health eligibility. Therefore, reviewers will consider HHA documentation if it is incorporated into the patient’s medical record and signed off by the certifying physician. More guidance will follow regarding the review of home health claims shortly. CMS apologizes for the confusion.”
Yesterday, a majority passed Medicare legislation that reforms the physician payment formula also known as the Sustainable Growth Rate (SGR). H.R. 2 will now go to the Senate where it is expected to pass.
The bill includes the previously reported provisions that affect home health and hospice services:
The annual payment rate update (Market Basket Index) is set at 1% in 2018. This represents an estimated 1 point reduction from what would otherwise be the update
A two year extension of the home health rural add-on at 3%. Under the bill, the add-on would expire with episodes beginning January 1, 2018 and later.
Modification of the home health surety bond requirements setting the bond minimum at $50,000 and allowing Medicare to scale the bond value up commensurate with the volume of Medicare revenue in the home health agency.
The Medicare beneficiary changes do not include a home health copay.
The bill “would institute a permanent fix in the physician payment methodology” which is good news for Medicare providers as there have been 17 previous “patches” that were financed by cutting provider payment rates.
Congress recently proposed a bill that would reset Medicare physician pay rates. However, details about the measure emerged that it would also include penalties as high as 100% for providers delinquent with income tax payments. According to the Government Accountability Office (GAO), thousands of Medicare providers are late paying their income taxes every year. Under the provision, the IRS would be allowed to impose late tax penalties as high as double the amount of the back taxes, reducing the offenders’ Medicare reimbursement checks. The current law sets the ceiling at 15%.
Insufficient documentation is one of the top issues leading to overpayments with payors on the lookout for any missing info in patients’ records. The biggest reason why provider documentation doesn’t hold weight usually has nothing to do with the codes selected and everything to do with a missing signature.
All medical notes must have an authorized signature. If any note in the medical record does not have an authorized signature, it will not be counted as valid documentation for the encounter.
When you’re performing self audits of your practice’s claims, make sure provider signatures are exactly where they should be. If a signature is missing during a self audit, you cannot simply have the provider add it. Signatures listed after the fact raise red flags for payors. Instead of adding signatures in, have your provider fill out and sign an attestation statement saying that he or she is the person who entered the data in the medical record for the patient on that date, and that all the information entered is valid. Keep this statement with the documentation for the encounter so it is easily accessible.
Bills to replace Medicare’s physician payment formula commonly known as the “doc fix” have passed the House and Senate committees but the final passage is not expected until 2014. The versions of the bill which would authorize a new payment system linking pay increases to quality care improvements was approved 39-0 by the House Ways and Means Committee and through voice vote by the Senate Finance Committee. The newly proposed legislation replacing the sustainable growth rate formula (SGR or “doc fix”) will freeze rates for 10 years for physicians who choose not to participate in the new pay-for-performance arrangement. Additionally, the bills approved would “combine Medicare’s existing quality programs-including meaningful use of electronic health records, the Physician Quality Reporting System and the value-based modifier-into one value-based performance program; incentivizes physicians to move from fee-for-service to payment models focused on coordination and prevention; and give more access to information to patients and physicians.” The formula would lead to a 20.1 percent cut in Medicare physicians rates in January without any congressional action.
The American Medical Association (AMA) recently reinforced its position that ICD-10 implementation should be delayed by two years. The AMA was instrumental in helping delay the ICD-10 implementation from October 1, 2013 to October 1, 2014. However, some experts say that this delay is only hurting physicians by giving them the idea that the AMA will be able to delay ICD-10 implementation once again.
So, how can we make physicians start taking ICD-10 implementation seriously? We can start by reminding them that ICD-10 will not change the way they practice medicine, it will only change the way they document it. In fact, ICD-10 is written more in clinical terms and less in coder speak so this may be important to physicians who already document necessary information about their patients. It is crucial that physicians are reminded not what they need to document, but what they are not documenting.