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Payment Matters
June 28, 2011
Meaningful Use Deadline for Eligible Hospitals and Critical Access Hospitals is Approaching
By: James B. Wieland and Joshua J. Freemire
Many Eligible and Critical Access Hospitals that intend to attest to Meaningfully Using Certified EHR Technology (and thus qualify for the significant available Incentive Program Funds) have already begun their reporting period in preparation for the 2011 attestation deadline. For those who have not, however, the time to begin is drawing to a close.
July 3, 2011 marks the last day that Eligible and Critical Access Hospitals may begin the necessary 90-day reporting period in time to attest and qualify for 2011 Meaningful Use Incentive payments. Failing to qualify for the incentive payment for 2011 does not disqualify providers from qualifying in later years, but it does mean that they will earn less incentive, in total, over the life of the Incentive Program.
Click to continue...District Court Upholds Offset of Medicaid Revenue Against Amount of Allowable Provider Taxes for Medicare Purposes
By: Carel T. Hedlund
Many states assess taxes against hospitals or other providers as a means of funding their Medicaid programs. The revenues generated by the taxes are used, with CMS’s approval, to fund Medicaid payments to various providers, and the federal government participates in these Medicaid payments by paying its share (called federal financial participation). Those providers reimbursed on a reasonable cost basis by Medicare have often claimed those taxes on their Medicare cost reports, and Medicare has been paying its share of those taxes. This practice is consistent with the general rule that taxes assessed against providers are allowable costs under Medicare reasonable cost principles. See Provider Reimbursement Manual§ 2122.
Click to continue...Streamlined Credentialing and Privileging Process Under the Final Telemedicine Rule
By: Sarah E. Swank and Aaron J. Rabinowitz
On May 2, 2011, CMS released the final telemedicine credentialing and privileging rule [PDF] clearing the way for credentialing agreements for telemedicine services between hospitals, as well as with non-hospital telemedicine entities. The final telemedicine rule follows on the heels of recent regulations promoting health care reform goals including providing cost effective and timely delivery of healthcare services. This telemedicine rule ends years of confusion for hospitals stuck in the middle of feuding between CMS and the Joint Commission (TJC) related to credentialing for telemedicine services. TJC previously allowed for “privileging by proxy” but CMS put its foot down, requiring hospitals after site surveys to change policies inconsistent with CMS Hospital Conditions of Participation. The final telemedicine rule requires that the hospital with patients in need of telemedicine services ensure through a written agreement that the parties meet certain credentialing obligations. Rural communities, which often suffer from a shortage of primary and specialty physicians and practitioners, will benefit from the ability to receive telemedicine services. Telemedicine may become more commonplace as the physician shortage becomes a reality. The effective date of this final rule is July 5, 2011.
Click to continue...Reminder: CMS Now Permits Electronic Submission of Medicare Graduate Medical Education (GME) Affiliation Agreements
By: Thomas W. Coons
As all teaching hospitals are aware, Medicare permits hospitals to share Medicare resident FTE cap slots through the use of Medicare Graduate Medical Education (GME) affiliation agreements. Historically, CMS has required that each hospital in the Medicare GME affiliated group submit the Medicare GME affiliation agreement to each hospital’s Medicare contractor, with a copy to the CMS central office, no later than July 1 of the residency year during which the agreement is to be in effect. See 42 C.F.R. § 413.79(f)(1). Too often, this has led to a scramble as hospitals have attempted to negotiate the final terms of an FTE sharing arrangement, memorialize those terms in a Medicare GME affiliation agreement, and mail those agreements by the July 1 deadline. Recently, however, CMS has provided some modest relief from this scramble.
Click to continue...June 30 Deadline Looms for the Electronic Prescribing Incentive Program
Providers who want to avoid next year’s financial penalty for a failure to make a sufficient number of electronic prescriptions will need to act quickly. Under the current eRx Program, providers must report the eRx measure for at least 10 unique Medicare encounters before June 30, 2011. Providers may report in several ways – a “fact sheet" [PDF] provided by CMS explains the available reporting options. Failing to report the required measures by the deadline may result in a provider receiving only 99% of the otherwise payable physician fee schedule payments due for services provided in 2012.
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