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July 1 deadline: Observation status coding could yield meaningful use penalty


 

July 1 is the deadline for hospitalists and other physicians to seek hardship exemptions from the federal government’s meaningful use electronic health record incentive program.

Many hospitalists don’t have to worry about attesting to meaningful use because they are considered "hospital-based" professionals who bill mainly for inpatient services. But frequent use of observation status, which is billed as an outpatient service, could shift hospitalists out of that exempt category and make them subject to meaningful use requirements and penalties.

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Under the meaningful use rules, if 90% or more of the services billed by an individual hospitalist are for inpatient services, they are automatically exempt from meaningful use. But the Society of Hospital Medicine is urging hospitalists to check their status because billing for observation status, billing at a skilled nursing facility, and other outpatient hospital billing could tip them over the threshold.

Hospitalists can check their status with the Centers for Medicare & Medicaid Services by going through the Medicare EHR Incentive Programs Registration System or calling the agency’s EHR Information Center Help Desk at 1-888-734-6433.

To avoid the 1% payment penalty in 2015, hospitalists who provide 10% or more outpatient services can seek a hardship exemption from the CMS. The hardship is based on the fact that hospitalists lack control over the availability of certified electronic health record technology for more than half of their patient encounters.

Hospitalists who want to avoid a penalty in 2015, must file a hardship exemption application by July 1, 2014. The online application and supporting documentation can be e-mailed to ehrhardship@provider-resources.com or faxed to 814-464-0147. The CMS makes hardship decisions on a case-by-case basis. If granted, the exemption must be renewed each year.

mschneider@frontlinemedcom.com

On Twitter @maryellenny

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