We all know about the Meaningful Use penalties. The PQRS penalties. The Value Based Modifier penalties. Individually, they’d all be annoying, but I don’t think most healthcare organizations have understood what these penalties will be in aggregate.
This hit home to me when I was reading a smartly titled post by Jim Tate called “What you don’t do in 2015 will cause 9% CMS penalties in 2017” Here’s how he describes the penalties that are in store for healthcare:
MU: Failing to achieve MU in 2014 will bring a 2% penalty beginning in 2016 with a 1% annual increase up to 5%.
Physician Quality Reporting System (PQRS): Non-participation brings a Medicare reimbursement reduction of 2.0% in 2016 based on 2014 data.
Value-Based Modifier(VBM): The VBM, which many providers are not aware of, is linked to PQRS. Beginning in 2016, eligible providers (EPs) in groups with 10 or more EPs will be subject to a penalty based on performance. In 2017, this will include all EPs, not just those in larger groups.
Taken together, this adds up to a 9% penalty in 2017 based on 2015 participation.
To avoid these penalties, immediately assess your current participation in the MU, PQRS, and VBM programs. If you are not on track you must take steps to mitigate your risk as soon as possible.
Risk mitigation is the right way to describe it. As I mentioned in the beginning, I don’t think that many providers are planning ahead to avoid these penalties. I also don’t think they realize the long term consequences of the choices they make today.
Thanks Jim for waking us up to the reality.