– Key Points Anesthesiologists
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Must Know The article discusses some important points that anesthesia providers need to know about Medicare Beneficiary Identifiers.
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Anesthesia reimbursement is complex and comes with unique challenges as experienced medical billing and coding companies know. Often, practitioners are not only faced with the unique challenge of effective billing and coding, but also ensuring they comply with all relevant payer regulations and standards. Anesthesiologists and Certified Registered Nurse Anesthetists (CRNA) often face several medical billing issues related to cancelled anesthesia, monitored anesthesia care, failed medical direction, invasive line placement rules, time issues and start/stop times. Therefore, it is important for anesthesiologists to adhere to rigid federal guidelines and check for even minor documentation errors which can lead to overbilling. In recent years, the Centers for Medicare and Medicaid Services have been transitioning from a fee-for-service payment system toward a system based on fiscal accountability and the provision of high-quality care. This transition received a huge boost on April 27, 2016 with the release of proposed rulemaking on the implementation of the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015. The Medicare Access and CHIP Reauthorization Act of 2015, (commonly known as MACRA) that came into effect on January 1, 2017 brings dramatic changes for Medicare beneficiaries and the providers that serve them, as it links physician reimbursement to quality of care rather than the volume of services. While experts say that the long-term impact of this policy on medical practices, medical billing companies and hospitals is uncertain, it is expected that the focus on quality will significantly improve efficiency and patient outcomes while reducing total costs.
MACRA – Bringing Big Changes for Anesthesiologists and CRNAs The Medicare Access & Chip Reauthorization Act of 2015 (MACRA) marked the end of Medicare’s fee-for-service model and the beginning of a performance-based payment system, the Quality Payment Program (QPP). The main objective behind the MACRA is to provide financial rewards for eligible clinicians who provide high-quality care through efficient resource utilization and who engage in quality improvement activities. Most anesthesia providers will be required to participate in MACRA. Healthcare providers have two main options to participate in MACRA – Advanced Alternative Payment Models (APMs) or the Merit Based Incentive Payment System (MIPS). The MIPS allows calculating a composite quality score, and rewarding or penalizing clinicians as in physician quality
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reporting system or value-based payment model. Under APM, a significant portion of care is reimbursed based on quality and costs. Under MACRA, facility-based clinicians such as anesthesiologists are described “non-patientfacing”. Non-patient-facing clinicians enjoy certain benefits and exemptions on the basis that these clinicians do not have significant control over the electronic health record and they need to coordinate with other stakeholders to engage in practice improvement activities. Therefore, non-patient-facing clinicians –
Are excluded from the advancing care information performance category
Have lower reporting requirement for practice improvement activities – requires reporting on only one high-weighted or two medium-weighted practice improvement activities.
MACRA ended the sustainable growth rate formula and inaugurated a new way of paying physicians in Medicare based on value. Even though MACRA is bringing dramatic changes for anesthesiologists and CRNAs, the main question that arises is how these changes will affect their practice and whether these changes may result in rejected and unpaid claims. Here are some important things that anesthesia providers need to know about MACRA and how it will affect their practice –
Removal of Social Security Numbers (SSNs) from all Medicare cards In order to protect seniors from identity theft and illegal use of Medicare benefits, the Department of Health and Human Services (HHS) will issue new Medicare cards that do not display code, or embed SSN (Social Security number). The new cards will use a unique, randomly assigned number called “Medicare Beneficiary Identifier (MBI)”. All beneficiaries will receive a new Medicare card by April 2019. Upon receiving their new card, beneficiaries need to safely and securely destroy their current Medicare card and keep their new MBI confidential. In addition, this upcoming card change will not affect a beneficiary’s Medicare benefits.
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Beneficiaries will receive a new Medicare Beneficiary Identifier (MBI) The new Medicare cards will replace the SSN-based Health Insurance Claim Number (HICN) currently used on Medicare cards with the Medicare Beneficiary Identifier (MBI). The MBI will–
Be clearly different from the HICN (Health Insurance Claim Number )
Be of 11-characters in length
Have alphabetic characters in the key positions 2, 5, 8, and 9
Be made up only of numbers and uppercase letters (no special characters)
Use the same number of digits as the HICN and occupy the same field as the HICN on transactions.
Be a Non-Intelligent Unique Identifier (which means they don't have any hidden or special meaning)
Be unique to each beneficiary (for example, husband and wife will have their own MBI)
Easy to read and limit the possibility of letters being interpreted as numbers (for example, alphabetic characters are upper case only and will exclude S, L, O, I, B, Z).
Transition period CMS plans to have a transition period wherein the beneficiaries can use either HICN or the MBI to exchange data. The transition period will begin no earlier than April 1, 2018 and run through December 31, 2019. During the transition period, CMS will actively monitor the use of HICNs and MBIs to see how many beneficiaries are ready to use only MBIs by January 2020. In addition, the transition and adjustment to the new MBIs will be monitored to check out their widespread adoption so that Medicare operations aren’t interrupted. Once the transition period ends on January 1, 2020, HICNs will no longer be exchanged with beneficiaries, providers, plans, and other third parties. The HICN will only be used for appeal requests, adjustments and related forms that were accepted using an HICN.
Failure to comply with MACRA will lead to claim denials Starting from January 1, 2020, claims will not be paid unless they are appropriately filed using the new “Medicare Beneficiary Identifier (MBI)”. Any claim submitted with the HICN will not be processed, resulting in significant delays in payments.
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ďƒ˜ MACRA requires complex system changes MACRA requires complex system changes affecting the federal and state governments, beneficiaries, providers and plans. These groups are investing millions of dollars in implementing system changes that may directly affect your Medicare claim filing process. MACRA accelerates the shift by CMS from paying for volume to paying for value-based service. The overwhelming majority of anesthesia providers will participate in MACRA via the Merit Based Incentive Payment System (MIPS) option. CMS analyzed the various comments and feedback that they received during the rulemaking process and created additional flexibility for 2017. All anesthesia providers should report some quality data in 2017 to avoid negative adjustment in 2019 payments. In addition, clinicians and groups need to understand the rule and position themselves to participate fully in 2018.
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