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compliance

Healthcare organizations must be compliant with changing healthcare trends, guidelines, laws, and government regulations to minimize risk.  Lineage Consulting will assist your organization with the implementation and strategic plan for multiple healthcare initiatives.

 

On April 16, 2015, President Obama signed into law the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). MACRA makes three important changes to how Medicare pays those who give care to Medicare beneficiaries. 

The law:

  • Repeals the Sustainable Growth Rate (SGR) formula for determining Medicare payments for health care providers’ services

  • Makes a new framework for rewarding health care providers for moving away from fee-for-service and toward payment based on value

  • Combines existing quality reporting programs (EHR Incentive Program, PQRS and VM) into one new system

These proposed changes, which have been named the Quality Payment Program, replace a patchwork system of Medicare reporting programs with a flexible system that allows you to choose from two paths that link quality to payments: the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs).

Most Medicare clinicians will initially participate in the Quality Payment Program through MIPS.

President Obama signed the Protecting Access to Medicare Act of 2014 (PAMA) into law on April 1, 2014. Congress passed the law up against the deadline to prevent Medicare physician payment cuts from taking effect, when efforts to reach an agreement on offsets to pay for a permanent physician payment fix fell short. The legislation also includes extensions for a number of other Medicare and Medicaid policies and some significant policy changes for multiple sectors of the health care industry. 

 

Appropriate Use Criteria for Physicians Ordering Advanced Imaging Services Provision

Under PAMA, the Centers for Medicare and Medicaid Services (CMS) will require physicians and other providers to consult appropriate use criteria (AUC) developed by a qualified provider-led entity (PLE) prior to ordering outpatient imaging services for Medicare patients.

  • An ordering provider must consult AUC for every Medicare Part B advanced imaging order (including CT, MRI, nuclear medicine and PET scans). Each claim will require evidence of consultation in order for it to be paid.

  • Providers who furnish this advanced imaging must document each consultation in order to receive reimbursement for their services.

  • Providers can access imaging AUC either by a stand-alone CDS system or via CDS software integrated into a practice’s electronic health record system.

In 2011, CMS established the Medicare and Medicaid EHR Incentive Programs (now known as the Promoting Interoperability Programs) to encourage eligible professionals (EPs), eligible hospitals, and CAHs to adopt, implement, upgrade, and demonstrate meaningful use of certified electronic health record technology (CEHRT).

In the Fiscal Year (FY) 2020 Medicare Hospital Inpatient Prospective Payment Systems (IPPS) for Acute Care Hospitals and the Long-term Care Hospital (LTCH) Prospective Payment System Final Rule, CMS finalized changes to the Medicare Promoting Interoperability Programs for eligible hospitals, critical access hospitals (CAHs), and dual-eligible hospitals attesting to CMS. 

The final rule adopted policies that will continue the advancement of certified electronic health record technology (CEHRT) utilization, further reduce burden, and increase interoperability and patient access to their health information. 

Participants in the Medicare Promoting Interoperability Program will be required to use 2015 Edition CEHRT.

Compliance Projects

MIPS ASSESSMENT & STRATEGIC PLAN

MIPS combines parts of PQRS, VM and the Medicare EHR Incentive Program into one single program in which clinicians will be measured on a scale of 0 to 100 using four performance based categories:  Quality, Resource Use, Promoting Interoperability, and Clinical Practice Improvement Activities. Lineage Consulting can assess and help streamline the collection of the data required by those three existing programs, and help identify additional workflow and requirements under MIPS. 

PAMA Assessment & strategic plan

The Protecting Access to Medicare Act (PAMA) requires that referring health professionals consider the appropriateness use criteria of all advanced diagnostic imaging services before they are ordered for Medicare patients. Lineage Consulting can assist practices with the shifting regulation requirements, and help Imaging Centers and Referring Provides comply with the AUC mandate.

ONC Health it certification

Lineage Consulting provides ONC HEALTH IT certification preparation and product analysis services to software vendors. By evaluating your software against the ONC certification criteria, Lineage Consulting aids in the generation of product pathways to achieve modular or complete EHR certification.​

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