Inpatient Facility Coding & Compliance Alert

Act in time to reap benefits in 2016.

The clock is ticking -- have you begun your participation in the Medicare Electronic Health Record (EHR) Incentive Program yet? 

“Electronic health record systems are rapidly becoming the de facto standard for all healthcare providers,” tells Duane C. Abbey, PhD, president of Abbey and Abbey Consultants Inc., in Ames, IA.

Facts for your fingertips: 2015 is the last year for eligible hospitals to begin and still earn incentive payments. 

To earn a 2015 incentive payment and avoid a 2016 payment adjustment, first-time participants should:

• Begin their 90-day reporting period no later than April 1, 2015.
• Attest by July 1, 2015. 
• Hospitals that successfully attest in 2015 will also be eligible to earn a 2016 incentive if they continue to participate.
• Eligible hospitals that begin participating after 2015 will not be able to earn incentive payments. They will also be subject to payment adjustments in 2016 and 2017.

Good news: Eligible hospitals that miss this deadline can still earn a 2015 incentive payment and avoid the 2017 payment adjustment if they begin their reporting period by July 1 and attest by November 30. However, they will be subject to the 2016 payment adjustment unless they apply and qualify for a hardship exception.

What is a hardship exception? Eligible professionals (EPs) and eligible hospitals may be exempt from payment adjustments if they can show that demonstrating meaningful use would result in a significant hardship. To be considered for an exception, an eligible hospital must complete a Hardship Exception application along with proof of the hardship. If approved, the hardship exception is valid for one payment year only. A new application must be submitted if the hardship continues for the following payment year. In no case may a provider be granted an exception for more than five years.

Are You the Chosen One for Hardship Exception?

Good news! Some providers will be granted a hardship exception automatically. CMS will use Medicare data on these providers to determine their hardship exception.

You do not need to submit a hardship application if you are:

• A new provider to the profession in your first year (both eligible professionals and eligible hospitals).

• An eligible professional who is hospital-based. A provider is considered hospital-based if he or she provides more than 90% of their covered professional services in either an inpatient (Place of Service 21) or emergency department (Place of Service 23) of a hospital.

• An eligible professional with 90 percent of claims including Place of Service 21, Place of Service 23, and certain observation services using Place of Service 22.

• An eligible professional who has been practicing anesthesiology, pathology, diagnostic radiology, nuclear medicine, or interventional radiology at least six months prior to the first day of the payment adjustments. 

Act in time to reap the benefits. “Any incentives that can provide funding should be pursued as appropriate,” insists Abbey. 

Here are some quick resources that you will need to get that well deserved extra incentive: 

• E health programs interactive time line: http://cms.gov/apps/interactive-timeline/

• Tip Sheet for eligible hospitals to calculate incentives: http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/MLN_TipSheet_MedicareHospitals.pdf

• Attestation user guide for eligible hospital and CAHS: http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/downloads/HospAttestationUserGuide.pdf

• Payment adjustment form hardship exception tip sheet for hospitals: http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/PaymentAdj_HardshipExcepTipsheetforHospitals.pdf.