Articles and Blogs

In response to COVID-19, the Centers for Medicare & Medicaid Services (“CMS”) has implemented multiple updates to the Merit-Based Incentive Payment System (“MIPS”) to relieve clinicians of certain reporting requirements including an extension for the 2019 performance year data submission deadline and the extension of the MIPS Extreme and Uncontrollable Circumstances policy for individual... READ MORE

Tuesday, April 28 Recap Note – ​We believe this is the most up-to-date information available at this time, but it is subject to change ​as circumstances warrant. Also, all finalized resources can be found ​on the COVID-19 ​Resource ​Center page ​of Hall Render’s website.​ Trump Administration Releases “Blueprint for Testing Plans and Rapid Response Programs” The... READ MORE

CMS recently posted reminders regarding the availability of MIPS final scores and the deadline to request review if an error has been made: “If you participated in the Merit-based Incentive Payment System (MIPS) in 2018, your performance feedback, which includes your MIPS final score and payment adjustment factor(s), are available for review on the Quality... READ MORE

On July 10, 2019, CMS issued proposed rulemaking titled Medicare Program; Specialty Care Models to Improve Quality of Care and Reduce Expenditures. The rule proposes to implement two new mandatory Medicare payment models – the Radiation Oncology Model and the End-Stage Renal Disease (“ESRD”) Treatment Choices Model. Comments on this proposed rule are due... READ MORE

CMS Releases Proposed Outpatient Pay Rule On July 25, the Centers for Medicare & Medicaid Services (“CMS”) issued the Medicare hospital Outpatient Prospective Payment System (“OPPS”) and Ambulatory Surgical Center (“ASC”) proposed rule for Calendar Year 2019, which contains an annual payment rate increase of 1.25 percent. Most significantly, the proposed rule would expand the... READ MORE

Eligible Professionals participating in the Medicare Meaningful Use Electronic Health Record Incentive Program have until October 1, 2017 to submit a hardship application to avoid a downward payment adjustment in 2018. A participant may submit a hardship application if the Eligible Professional: Is a first-time Eligible Professional who intends to participate in the advancing care information performance... READ MORE

Ordinarily, CMS will calculate the MIPS final score for a practice group’s physicians on an individual or group basis.[1] However, physicians participating in a “MIPS APM” are subject to a significantly different scoring methodology – the “APM scoring standard.” This article: (1) outlines CMS’s “snapshot” process for determining which physicians CMS will score using... READ MORE

The Cures Act addresses certain electronic health record (“EHR”) difficulties faced by physicians who practice primarily in ambulatory surgery centers (“ASCs”). Section 16003 explicitly excludes physicians who furnish substantially all of their Medicare services at ASCs from the penalties imposed under various programs for failure to adopt a certified EHR. Under the current Medicare... READ MORE