New Fiscal Year

Future OutlookInteresting that all I wanted to do is provide a synopsis and instead spent days diving into research so I could be certain of what was the most current information which sadly to said may be obsolete in a couple of months.  Regardless, some of my findings merit to be mentioned so here they are: ICD 10.  While most provider and organizations didn’t have too much trouble with ICD 10’s the best is yet to come.  The new update for ICD 10 is already in the pipeline and based on First Coast it will be installed in their systems as early as October 1st, 2016. The Health Insurance Portability and Accountability Act of 1996 (HIPAA) requires that covered entities use the standards adopted under this law for electronically transmitting certain health care transactions, including health care claims.   This means that healthcare providers and organizations need to be ready to use the new codes as of October 1st, 2016. Based on our own research we expect to see at least 75,625 ICD-10-PCS codes for fiscal year (FY) 2017. Of that number, 3,651 are new codes and 487 are revised. And of those new codes, a whopping 3,549 (97 percent) are in the cardiovascular system section alone. Also, as of October 1st, 2016 the Centers for Medicare and Medicaid Services (CMS) will end a year-long grace period for its specificity grace period.   In other words, after several organizations raised their concerns regarding the implementation of ICD 10 CMS agreed to allow a one-year grace period for ICD-10 flexibility.   This meant that as long as claims submitted to Medicare and Medicaid contained ICD-10 codes in the correct “family of codes the same were to be paid. We don’t know the impact this will have but we do expect challenges based on the amount of new codes and the end of the grace period. Meaningful Use.  October 2nd is the last day to start and complete a 90-day reporting period in 2016. CMS has also indicated that the 90 day reporting period will be applicable to all participating providers. Failure to demonstrate Meaningful Use for CY 2016 can result in a payment adjustment of up to 4% on Medicare Part B reimbursements in 2018. Objectives and Measures

  • All providers are required to attest to a single set of objectives and measures.
  • All providers are now in Stage 2 of Meaningful Use — with a “Modified Stage 2” for providers that were previously in Stage 1.
  • Every provider will now be completing a 90-day reporting period for the 2015 reporting year.
  • The Stage 2 measures that required patient engagement have been greatly reduced.
  • Attestation will not be available to providers until January 4, 2016. The current attestation deadline is February 29, 2016.
  • For eligible professionals (EPs), there are 10 objectives, and for eligible hospitals and critical access hospitals (CAHs), there are 9 objectives.
  1. Protect Patient Health Information: Protect electronic health information created or maintained by the CEHRT through the implementation of appropriate technical capabilities. Covered entity must be in full compliance with HIPAA Security requirements.
  2. Clinical Decision Support (CDS): Use clinical decision support to improve performance on high priority health conditions.
  3. Computerized Provider Order Entry (CPOE): Use computerized provider order entry for medication, laboratory, and radiology orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local, and professional guidelines.
  4. Electronic Prescribing: (EPs) Generate and transmit permissible prescriptions electronically (eRx); (Eligible hospitals/CAHs) Generate and transmit permissible discharge prescriptions electronically (eRx).
  5. Health Information Exchange: The EP, eligible hospital or CAH who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care provides a summary care record for each transition of care or referral.
  6. Patient Specific Education: Use clinically relevant information from CEHRT to identify patient specific education resources and provide those resources to the patient.
  7. Medication Reconciliation: The EP, eligible hospital, or CAH who receives a patient from another setting of care or provider of care or believes an encounter is relevant performs medication reconciliation.
  8. Patient Electronic Access: (EPs) Provide patients the ability to view online, download, and transmit their health information within 4 business days of the information being available to the EP. (Eligible hospitals/CAHs) Provide patients the ability to view online, download, and transmit their health information within 36 hours of hospital discharge.
  9. Secure Electronic Messaging (EPs only): Use secure electronic messaging to communicate with patients on relevant health information.
  10. Public Health Reporting: The EP, eligible hospital or CAH is in active engagement with a public health agency to submit electronic public health data from CEHRT, except where prohibited and in accordance with applicable law and practice.

In 2016, all providers must attest to objectives and measures using EHR technology certified to the 2014 Edition. If it is available, providers may also attest using EHR technology certified to the 2015 Edition, or a combination of the two. Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). MACRA was signed into law on April 16, 2016 but the final regulations will not be released until Nov 2016. One of the key components of MACRA is the consolidation of three existing programs into one:

  1. Physician Quality Reporting System (PQRS),
  2. Physician Value-Based Payment Modifier (VM),
  3.  Medicare Electronic Health Record (EHR) Incentive Program

 Note: It is expected that these programs will cease to exist as individuals in 2019 but will simply be part of MACRA. There are two basic program categories for eligible clinicians to participate under:

  • The Merit-based Incentive Payment System (MIPS).
  • Advanced Alternative Payment Models (APMs)

 Note: The main difference between the MIPS and APMs programs are that APMs require practices to take on more financial and technological risks. Under MACRA, and at this time, the only eligible clinicians are: Physicians, physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists, and groups that include these clinicians. MIPS eligible clinicians will receive payment based on a composite score for their performance in four domains:

  1. Quality (replaces PQRS and the VM). Fifty percent of the total score in year #1, 45% in year #2, and 30% in 2021 and beyond). Physicians choose six quality measures to report on from an extensive list of options tailored to each specialty and practice.
  2. Advancing Care Information (formerly Meaningful Use [MU]). Twenty-five percent of the total score in year #1, 25% in year #2, and 25% in 2021 and beyond). Clinicians report customizable measures with an emphasis on interoperability and information exchange. CMS has made some notable changes to MU. According to the proposed rule, this domain aims to “support the vision of a simpler, more connected, less burdensome technology.” The proposal will “allow physicians and other clinicians to choose to select the measures that reflect how technology best suits their day-to-day practice.” Clinicians also won’t need to report on measures related to Clinical Decision Support (CDS) and Computerized Physician Order Entry (CPOE).
  3. Clinical Practice Improvement Activities. Fifteen percent of the total score in year #1, 15% in year #2, and 15% in 2021 and beyond). Clinicians are rewarded for activities such as care coordination, beneficiary engagement, and patient safety. More than 90 reporting options are available, and clinicians also receive credit for participating in APMs and Patient-Centered Medical Homes.
  4. Cost (replaces the VM). Ten percent of the total score in year #1, 15% in year #2, and 30% in 2021 and beyond). This score is based on Medicare claims and does not require any additional reporting. The category uses more than 40 episode-specific measures.

CMS’ September 8, 2016 Announcement. CMS intends to allow physicians to pick their pace of participation for the first performance period that begins January 1, 2017. The key point of this is that clinicians that choose at least one of these options would avoid a negative payment adjustment in 2019. The details of these options will be described in the final rule but some of the basics are:

  • First Option: Test the Quality Payment Program.  Submit some data to the Quality Payment Program, including data from after January 1, 2017,.
  • Second Option: Participate for part of the calendar year.  Submit Quality Payment Program information for a reduced number of days. This means you may start after January 1, 2017 and your practice could still qualify for a small positive payment adjustment.
  • Third Option: Participate for the full calendar year.  Submit Quality Payment Program information for a full calendar year.
  • Fourth Option: Participate in an Advanced Alternative Payment Model in 2017. Instead of reporting quality data and other information, the law allows you to participate in the Quality Payment Program by joining an Advanced Alternative Payment Model, such as Medicare Shared Savings Track 2 or 3 in 2017. Participating in an Advanced Alternative Payment Model in 2017 may qualify you for a 5 percent incentive payment in 2019.

As I always say, we live in interesting times so stay tuned for more.