Christmas has come early for eligible professionals (EPs) wanting to reassign their EHR incentives payments to Method II critical access hospitals (CAHs) care of the Centers for Medicare & Medicaid Services (CMS). The federal agency has issued a final rule for the Medicare and Medicaid Programs which impacts this subject of providers demonstrating meaningful use as part of the EHR Incentive Programs.
Having upgraded its systems for identifying the National Provider Identifiers (NPIs) of these EPs, CMS is now in a position to process “take into account the services furnished by EPs in Method II CAH outpatient settings when we annually determined the hospital-based status of each EP for each payment year for purposes of the EHR Incentive Program.” The upgrade impacts claims submitted no earlier than the beginning of Oct. 1, 2012, the start of Fiscal Year 2013.
CMS has decided on a two-step process for handling payment year 2013 only. The first step involves identification of these newly-defined hospital-based EPs:
First, after we have accumulated the Method II CAH claims with the line-level furnishing EP identifying information for FY 2013 (October 1, 2012 through September 30, 2013), we will use that data to identify which EPs had Method II CAH service billings during that year, and we will make a special hospital-based determination for that subset of EPs for payment year 2013. Any EP determined to be nonhospital-based on the basis of FY 2013 claims data will be eligible to demonstrate meaningful use for the relevant EHR reporting period and potentially qualify for an EHR incentive payment for payment year 2013.
The second step requires the comparison of FY 2013 and FY 2012 data:
Second, in the case of an EP determined to be hospital-based on the basis of FY 2013 claims data, we will check the hospital-based determination we have already for that EP under the existing regulation using the FY 2012 file. Any EP found to be nonhospital-based on the basis of the FY 2012 claims data (which do not include Method II CAH claims) will be held harmless to the determination made on the basis of FY 2013 claims data and considered nonhospital-based for payment year 2013.
In order to the amount of the final EHR incentive payment to the Method II CAH, CMS has indicated that it “will use the most recent 12-month cost reporting period available at the time of final settlement” for instances where “there is no 12-month cost reporting period that begins on or after the beginning of a payment year.”
At the beginning of 2013, the American Hospital Association urged CMS to address the eligibility criteria for the EHR Incentive Programs that affect these physicians using the Method 2 billing approach prior to the Feb. 28, 2013, deadline for EPs to receive maximum incentives. Source
