The problem with physicians and critical-access hospitals has been the subject of a short volley of letters since December between the American Hospital Association and the CMS. At issue was the inability of the CMS to use claims from critical-access hospitals to qualify physicians and other professionals under the Medicare EHR incentive program if the hospitals used the Method 2 billing procedure. Under this method, a critical-access hospital bills Medicare on behalf of the physician for outpatient services covered under the Medicare Physician Fee Schedule.
Neither the AHA nor the CMS responded to requests for comment by deadline.
In its fact sheet, the CMS said in order for CAH physicians to participate, it is “implementing system changes to capture their National Provider Identifier and line-of-service payment information. This ensures their claims are tied to the specific services rendered.” The CMS statement said the physicians at CAHs billing under Method 2 “can begin participation in calendar year 2013.”
But that means these physicians and other professionals won't be able to attest before the Feb. 28, 2013, deadline for the Medicare EHR incentive payment program that if they've met meaningful-use guidelines in 2012. And that means, they won't be paid the maximum amount of incentives under Medicare—a total of $44,000—but only a maximum of $39,000, since the Medicare program begins a stair-step series of payment reductions as it winds down beginning in 2013. Also, their first-year payment will be lower, $15,000 versus $18,000, and they'll lose a fifth-year payment of $2,000.
Under the Medicare portion of the program, physicians and other professionals in their first year of participation must attest to having used a certified EHR to meet Stage 1 meaningful-use criteria for 90 consecutive days during a calendar year.
Physicians who are eligible to participate in the Medicaid EHR incentive payment program—which runs longer and does not stair-step payments—will still be eligible to receive the full payment of $63,750 even if they don't attest until 2014. Under the Medicaid portion, physicians and other professionals in their first year need only attest they've either adopted, implemented or upgraded to a certified EHR.
