CMS recently announced changes to the chronic care management and meaningful use programs for 2015, in the case of both programs, slightly easing the requirements. Here are updates to our recent blog posts on both programs:
Chronic Care Management
For the chronic care management code program launching January 2015, CMS announced that instead of the G-code proposed, chronic care management should be billed under CPT code 99490.
CMS also announced that the payment rate will be $42.60 for a one per month per patient CCM code, a slight increase from the originally proposed rate of $41.92.
Additionally, CMS finalized revisions regarding “incident to” services. Under these revisions, CCM services provided by clinical staff incident to the service of a practitioner can be furnished under general supervision of a physician or other practitioner and the clinical staff need not be a direct employee of the practitioner or practitioner’s practice.
Finally, CMS announced that rather than require 2014 certified EHR software, they would relax that requirement and will instead require the version of the certified EHR in use on December 31 of the prior year for the EHR Incentives Programs to bill for CCM services.
For a more in-depth explanation of this program and how it can benefit practitioners, see our previous blog post on the new chronic care management code program.
New Meaningful Use Hardship Exception
CMS has also announced the addition of a new “extreme and uncontrollable circumstances” hardship exception for eligible providers to avoid penalties for failing to meet Meaningful Use, according to a final rule in the Federal Register.
As reported in an article in EHR Intelligence, “the federal agency admits that the impetus for this hardship exception was the confusion caused by recent rule changes intended to give eligible providers greater flexibility for achieving meaningful use in reporting year 2014 using the certified EHR technology available to them.”
The final rule says that “Providers were extremely concerned that their inability to use the flexible options specified in the 2014 CEHRT Flexibility rule would subject them to a payment adjustment in 2015 under Medicare for failing to demonstrate meaningful use of CEHRT.”
These concerns were exacerbated by a delay in updating CMS attestation website, as we reported here. The CMS Registration and Attestation System did not allow eligible providers attesting for the first time to choose the flexibility options before Oct. 1 of this year and successfully avoid meaningful use payment adjustments in 2015.
In order to qualify for the “extreme and uncontrollable circumstances” hardship exception, EPs must meet two criteria:
- The provider must not have been able to fully implement the 2014 Edition CEHRT due to delays in 2014 Edition CEHRT availability.
- The provider must not have been able to attest by their attestation deadline in 2014. For example, for eligible professionals, the eligible professional must not have been able to attest by October 1, 2014 using the flexibility options under the 2014 CEHRT Flexibility rule.
But note that there isn’t much time to file for the exception: EPs have until November 30, 2014, to apply.
Finally, CMS is apparently setting the stage for future rules that will address new and emerging hardships in the coming year:
“Accordingly, to ensure that we do not face similar timing constraints in the future and to reduce administrative burden on providers who wish to request a hardship exception,” CMS continues, “we are amending the regulation text for the other hardship exception categories to enable CMS to specify a later deadline for submission of hardship exception applications.”
To learn more about the chronic care management program, Meaningful Use and other CMS programs, visit our Resource Center where you’ll find live and recorded webinars, white papers, infographics and more.