Attention rural clinics and critical access hospitals; please review the information below regarding PQRS:
What clinics are subject to PQRS penalties?
ANY clinic who submits a Medicare Part B claim using the 1500 claim form is subject to PQRS penalty. If penalty occurs, it will only occur on this claim, not other Medicare claims. Certified Rural Health Clinics do not typically submit Medicare Part B claims as they are not physician fee schedule claims.
For eligible clinics that have been submitting qualifying data to CMS throughout the year, the deadline for submitting any 2014 data is February 28, 2015. For eligible clinics who have not been submitting data throughout the year, they will be subject to penalty.
What Critical Access Hospitals (CAHs) are subject to PQRS penalties?
Method I CAHs do not submit fee schedule claims and are not subject to PQRS. If a Method I CAH owns a physician practice or other business arrangement that submits Medicare Part B fee claims, those would be subject to PQRS penalty.
Method II CAHs submit fee schedule claims on behalf of physicians, so beginning in 2016 those claims are subject to PQRS based on 2014 performance, as long as the rendering clinician NPI is included on the claims. Fee schedule claims from 2013 should not lead to a penalty in 2015. Any fee schedule claims for services delivered outside a RHC would be subject to PQRS, as would any services delivered at a Method I CAH.
There is no exemption for low volume of fee schedule claims or hardship. Method II CAHs’ physicians are not subject to PQRS penalties in 2015 based on 2013, because their claims couldn’t be accepted for the program’s purposes until 2014.
New for the 2015 PQRS program year, EPs in Critical Access Hospital Method II (CAH II) may participate in the PQRS using all reporting mechanisms, including the claims-based reporting mechanism via the CMS-1450 form. Regardless of the reporting mechanism, CAH II providers will need to continue to add their NPI to the CMS-1450 claim form for analysis of PQRS reporting at the NPI-level.
**However, a small number of physicians (or the CAHs) slipped through the cracks and received a letter in error. CMS has identified them and corrected the system so that they won’t be penalized. If facilities think that may be the case regarding the letter they received (if they received one), call the Quality Net Help Desk (info below), which has a corrected list of the physicians to which the penalty is applicable in 2015. The letters were sent to the best available address in PECOS, which is why some went to CAHs and RHCs. The key is to check the TIN/NPI listed in the letter, which refers to the practice that will be penalized.
Questions
If there is any question, each physician who received a letter should submit a request for an informal review. To request an informal review: https://qualitynet.org/portal/server.pt/community/informal_review_request/
To check TIN or NPI to see if a provider is subject to an incentive or payment adjustment. Please go to the bottom left hand corner of the following webpage: https://www.qualitynet.org/portal/server.pt/community/pqri_home/212
FAQ 2015 PQRS Payment Adjustment Letters RHCs/FQHCs PQRS List of Eligible Professionals PQRS Penalties 2015 PQRS Payment Adjustment
For More Information
For more information on the quality measures that qualify for PQRS, the reporting requirements and the clinical data registry options, please see the below resources. For any further questions regarding clinics, contact Sara Leahy at sl@coruralhealth.org or 303-565-5848; regarding hospitals, contact Caleb Murphy-Siem at cm@coruralhealth.org or 303-468-3498.
Centers for Medicare and Medicaid (CMS)
Quality Net Help Desk for PQRS
866-288-8912 or qnetsupport@hcqis.org (please note that phone calls will be put on hold for up to 30 mins and email responses will take up 10 days)
http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/Spotlight.html
National Association for Rural Health Clinics (NARHC)
info@narhc.org
Telligen
Devin Dettwiler, Manager Quality Improvement
ddetwiler@telligen.com
