January 10, 2011

Registration for the Medicare incentive bonus for “meaningful use” of an electronic health record (EHR) is now open. CMS is encouraging all eligible professionals (EPs) to register promptly even if they do not have a qualifying EHR system in place.

With a potential bonus of up to $44,000 over five years, it is in most anesthesiologists’ and pain physicians’ interest to sign up. Registering does not obligate you to participate, but if you eventually install a certified EHR and decide to participate, registering now will expedite the enrollment process.

All that is necessary, if you are an EP (physician, dentist, optometrist, podiatrist or chiropractor -- but not nurse anesthetists or anesthesiologists assistants) is:

• An active National Provider Identifier (NPI),
• An enrollment record in the Provider Enrollment, Chain, and Ownership System (PECOS), and 
• A National Plan and Provider Enumeration System (NPPES) web user account. You would use your NPPES user ID and password to log into the system at https://ehrincentives.cms.gov/hitech/login.action to register.

To earn the bonus in 2011, in the amount of $18,000 per physician, you should return to the same website and attest that you have made “meaningful use” of a certified EMR for 90 days, by October 1. You may begin in 2012 or later and qualify for a pro rata incentive payment.

There is a separate Medicaid incentive program that offers up to $63,750 per provider. Since a 30 percent Medicaid case mix is required to earn this bonus, we are not discussing the program further, except to say that the states will administer the Medicaid EHR incentives and participant registration.

Incidentally, more than 50% of physicians are now using at least a basic EHR, according to a survey mailed to 10,301 physicians by the CDC in 2010. Only about 10 percent of office-based physicians have a "fully functional" EHR, though.  See today's issue of American Medical News online.

CMS has produced an excellent user guide to the Medicare EHR incentive program, ABC will register client physicians automatically.

More on Medicare Payment Rates for 2011

In our Alert of January 3, 2011, we included Medicare’s new conversion factors for anesthesia services. ASA is seeking to validate the CMS calculations but is stymied by the lack of information on CMS’ methodology. ASA has submitted formal “comments” on the 2011 Final Physician Fee Schedule Rule in which it requests clarification from the Agency.

The comment letter also asks CMS to accept the recommendation from the AMA/Specialty Society Relative Value Update Committee (the “RUC”) to assign 1.90 “work” RVUs to CPT® code 64483, transforaminal epidural injection. CMS disregarded the AMA recommendation in finalizing this year’s Physician Fee Schedule and value code 64483 at 1.75 RVUs. The dollar difference is 0.15 RVUs x $33.98 (the non-anesthesia CF) or $5.10 per injection.

The non-anesthesia CF, which has decreased from $36.88 to $33.98, does not mean that the allowed payment for each individual service will be eight percent lower than last year. CMS performed a reweighting of the work, practice expense and professional liability insurance expense components of the Relative Value Scale that reduced the numerical value of the CF – but the net impact of these changes is budget neutral. Thus Medicare payments for some codes will be higher, and for others will be lower in 2011. The net impact on interventional pain management, for example, will be 0% in 2011, transitioning to 2% when the reweighted RVUs are fully phased in.

ASA has posted on its website a comparison of 2010 and 2011 payments for select RBRVS procedures performed by anesthesiologists and pain physicians. In Table 1 below are some of the changes in payments for five familiar procedures done in the hospital or ASC (“facility”) as opposed to a private office, taken from the ASA table. Note that the RVUs here are not geographically adjusted, so your own, local Medicare payments may be different again.

Table 1. Comparison of 2010 and 2011 Medicare Allowed Amounts for 5 RBRVS Procedures Performed Frequently by Anesthesiologists and Pain Physicians

The examples in Table 1 are just that, examples. You cannot extrapolate from them, but you can determine the change in allowed amounts for the procedures of interest to your practice. Use the complete data in the ASA spreadsheet and multiply the work, practice expense and professional liability expense RVUs by their respective geographic practice cost index (GPCI) values using the formula:

[(Work RVU * Work GPCI)
+ Facility or Non-Facility PE RVU * PE GPCI)
+ (PLI RVU * PLI GPCI)]
* CF

Once CMS has updated the database on its Physician Fee Schedule Search page to include the 2011 RVUs, you will be able to look up the facility or non-facility allowed amount by code and by Medicare locality. If you are not already familiar with this tool, you might want to make a note of it.

As always, we hope that the information in this and our other Alerts is useful to you, and that you will let us know if we can help answer questions.

With best wishes,

Tony Mira
President and CEO