Question:
We represent a Rural Health Clinic (RHC) and/or Federally Qualified Health Center (FQHC) that received a letter from CMS in 2014 stating on January 1, 2015, we will begin receiving the 2015 PQRS negative payment adjustment on all Part B covered professional services under the Medicare Physician Fee Schedule (MPFS). Why are we receiving this? We thought we were ineligible.
Answer:
Services furnished by RHCs and FQHCs are not eligible for the PQRS incentive payment and are not subject to the PQRS negative payment adjustment. Only covered professional services furnished by eligible health care professionals (EPs) that are paid under the Medicare Physician Fee Schedule (MPFS) are eligible for PQRS.
Please review the Tax Identification Number (TIN)/National Provider Identifier (NPI) combination included in the letter received from CMS, as this is the individual provider to whom the 2015 payment adjustment will apply, not the clinic or facility. An example of why a physician who practices at an RHC/FQHC may be subject to the 2015 payment adjustment is that (s)he bills non-RHC or non-FQHC services under the MPFS via the 1500 claim form. The provider’s contact information used to send the 2015 PQRS negative payment adjustment letters was gathered from the Provider Enrollment, Chain, and Ownership System (PECOS). Letters that include only a TIN apply to the entire group practice as the TIN is registered to participate in the 2013 PQRS GPRO. The group’s contact information used to send the 2015 PQRS negative payment adjustment letters was gathered from the 2013 PQRS GPRO registration or self-nomination system.
CMS would also like to remind participants that there are no hardship or low volume exemptions for the PQRS payment adjustment. All EPs who billed Medicare Part B for non-RHC/FQHC services in 2013 must have satisfactorily reported PQRS in order to avoid the 2015 negative payment adjustment.
As outlined in the 2015 PQRS payment adjustment letter, if you believe that the 2015 PQRS payment adjustment is being applied in error, you can submit an informal review request. All informal review requests must be submitted via a web-based tool, the Quality Reporting Communication Support Page (Communication Support Page), during the informal review period, January 1, 2015 through February 28, 2015.
Please contact the QualityNet Help Desk at 1-866-288-8912 (TTY 1-877-715-6222) or via qnetsupport@hcqis.org for help with questions. They are available from 7:00 a.m. to 7:00 p.m. Central Time Monday through Friday.
