On March 6, 2015, CMS released an MLN Matters article (#SE1508), updating guidance on the 2015 payment adjustments for Rural Health Clinics (RHCs), Federally Qualified Health Centers (FQHCs), and Critical Access Hospitals (CAHs), based on Physician Quality Reporting System (PQRS) data for the 2013 reporting year. 

As required by the Affordable Care Act, eligible professionals (EPs) who failed to satisfactorily report 2013 PQRS data are subject to a negative payment adjustment of 1.5 percent of allowed Medicare Part B Physician Fee Schedule (PFS) amounts for calendar year 2015.  In 2016, the adjustment will increase to negative 2.0 percent, based on 2014 PQRS reporting data.  EPs that successfully reported data for 2013 and 2014 will not only avoid the payment adjustment in 2015 and 2016, respectively, but they are further eligible for an incentive payment.  The incentive payment program ends after the 2014 PQRS reporting period.

The MLN Matters article clarifies the applicability of the payment adjustment to certain service sites.  According to CMS, EPs who furnish professional Part B services only at an RHC or FQHC are not subject to the negative payment adjustment, nor eligible for the incentive payment.  However, should an EP also furnish services at a non-RHC or non-FQHC site, those additional services would be subject to the negative adjustment and potentially qualify for the incentive payment.

Professionals furnishing services outside of RHC or FQHC sites must report data or be subject to the adjustment when: (1) the services are billed under the EP’s own Tax Identification Number (TIN) or National Provider Identifier (NPI) via the Provider Enrollment, Chain and Ownership System (PECOS); or (2) the services are billed under a group practice’s TIN, in which case the adjustment will apply to the entire group practice.

The MLN Matters article also make clear that EPs furnishing professional Part B services at a CAH, if the CAH is paid under the Optional Payment Method (Method II), are also ineligible for the 2013 PQRS incentive payment or the 2015 PQRS negative payment adjustment.  However, starting with 2014 (and the associated adjustment in 2016), a Method II CAH EP will be subject to payment adjustment if he or she fails to properly report PQRS data.

The MLN Matters article is available here.

Reporter, Elizabeth N. Swayne, Washington, D.C., +1 202 383 8932, eswayne@kslaw.com.