News & Insights

You can still avoid a QPP Penalty without an EHR!

November 02, 2018

Natalie Cohen, MBA, MHA


You can still avoid a QPP Penalty without an EHR!

Do you see the N700 remark code on your Medicare EOBs?

If your EOBs from Medicare include this remark code, you are currently getting a 4% penalty!

Meaningful Use (MU) was created as an EHR incentive program to encourage providers to adopt Certified Electronic Health Record Technology in their practices. However, beginning in 2015, Medicare eligible professionals who were not meaningful users of EHR technology were subject to payment adjustments

The good news is, this four percent Meaningful Use reduction on payments in 2018 will end after December 31, 2018. The Meaningful Use penalty will apply to all payments for services rendered in calendar year 2018. Once those claims are paid out, the Meaningful Use penalty will end.  

Meaningful Use Changes to Promoting Interoperability

The Meaningful Use Program was rolled into the Quality Payment Program (QPP) in 2017. It was one of the three Merit Based Incentive Program (MIPS) performance categories in the QPP and was renamed Advancing Care Information (ACI). The requirements for ACI were similar to those of the pre-QPP Meaningful Use Program. In April of 2018, the performance category was renamed again to Promoting Interoperability, but the requirements remained the same. 

In 2017 and 2018, the ACI/PI performance category counted for 25 out of the 100 points of an eligible clinician’s MIPS Composite score.  

No EHR? No problem!

The 2018 QPP regulations allow small practices (under 15 providers) to apply for an exemption from the EHR utilization requirement.  

The eligible group or clinician WILL NOT BE EXEMPTED FROM THE QPP, simply the requirement to use a Certified EHR. The application is online and very simple. It can be completed by the provider, manager or other staff member. The application can be completed for an individual or a group. 

The eligible group or individual will still need to submit data from the Quality performance category and/or the Improvement Activities performance category to earn the minimum 15 points needed to avoid a five percent penalty in 2020. The 25 points will be added to the Quality category so the final score will still be based off a 100 point scale.  

It is important to evaluate how they will report (e.g. individual or group) BEFORE completing the Promoting Interoperability Hardship Application.  

Need help?

There is no charge for our consultation. These services are provided to you because you are a LAMMICO insured. Participation in the Quality Payment Program can also help you mitigate your malpractice risk through tracking and improving quality care (Quality measures), increasing patient engagement and satisfaction (Improvement Activities) and improving communications using secure electronic transmissions between providers and with patients (Promoting Interoperability).  

Contact LAMMICO Practice Management Specialist, Natalie Cohen, MBA, MHA, at 504.841.2727 or ncohen@lammico.com

This is not legal or financial advice, and is not intended to substitute for individualized business or financial judgment. It does not dictate exclusive methods, and is not applicable to all circumstances.

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