The Centers for Medicare & Medicaid Services has issued updated guidance that explains how certain physicians who provide services in the outpatient departments of critical access hospitals can participate in the Medicare Electronic Health Record Incentive Program beginning this year. The affected physicians are those for whom a CAH bills Medicare for their outpatient department services using optional Method II.
Under this method, the CAH bills Medicare on behalf of the physician for services covered under the Medicare Physician Fee Schedule. Due to system constraints, CMS did not include these Method II claims when it identified which physicians were eligible for its incentive programs.
As a result, Method II physicians were inappropriately excluded from the EHR incentive program because they were designated as "hospital-based" when they are not. In response to concerns raised by the American Hospital Association and others, CMS is implementing system changes to allow these physicians to participate.