As many of you know, physicians employed or contracted with Critical
Access Hospitals who billed those services using Method II have been unable to
earn CMS EHR Incentive payments (this does not apply to Medicaid incentives if
they qualify).
The problem has been that while Method II claims are adjudicated
and paid by CMS as Part B claims, they are submitted using a UB02 or
institutional claim form. While most every CAH ensures that these claims for
Method II services included the rendering physician's NPI number, the CMS
claims system was unable to capture that at the line level. CMS physician
incentives are paid by calculating 75% of the Part B allowable submitted to CMS
in the calendar year up to the current incentive program maximum. For this year
the maximum incentive is $15,000.
Since CMS could not pull the Method II claim line items and
associate those to a physician NPI, there has been no way to calculate the
incentive payment. This unfortunate oversight when creating the incentive
program and in CMS's systems has delayed the ability to capture incentives for Method
II physicians.
CMS announced the "fix" late last year; in a
recently released FAQ this has been confirmed. Physicians cannot attest before
January 1 for this calendar year and must be sure they have properly registered
on the CMS Incentive site as well as have their payment assignments with their
CAH in proper order.Attestation will be for 90 days of Stage 1 Meaningful
Use.
CMS states:
If a provider would like to qualify for an EHR incentive payment and is reassigned to a CAH, this information may be verified through PECOS once an 855R form is submitted for an enrolled provider/supplier. If the provider is not currently enrolled, 855I and 855R forms must be submitted and processed. CMS is now accepting these forms for reassignment of payments to CAHs. Medicare may pay: (1) a physician or other supplier’s employer if the supplier is required, as a condition of employment, to turn over to the employer the fees for his or her services; or (2) an entity (i.e., a person, group, or facility) that is enrolled in the Medicare program for services furnished by a physician or other supplier under a contractual arrangement with that entity. This means that Part A and Part B entities other than physician/practitioner group practices can receive reassigned benefits, assuming the requirements for a reassignment exception are met and that the reassignee meets all enrollment requirements.
If you have any questions please contact our Senior Advisor, David
Ginsberg. We urge all of our CAHs with Method II billing for physicians in
place, and who have otherwise reached meaningful use for their clinic systems
to follow through for their CMS EHR Incentive.
