Physicians face an "imminent storm" of mass confusion caused by overlapping regulatory mandates and reporting requirements from multiple federal programs unless federal officials do something to prevent it, TMA and other state and national medical societies warn in a letter to Centers or Medicare & Medicaid Services (CMS) Acting Director Marilyn Tavenner.
The groups are concerned about regulations and penalties associated with the value-based modifier; about penalties under the electronic prescribing program, the Physician Quality Reporting System, and electronic health record incentive program; and about the transition to the ICD-10 coding system.
TMA's Calendar of Doom helps physicians keep up with all the deadlines they have to meet.
"We urge CMS to re-evaluate the penalty timelines associated with these programs and examine the administrative and financial burdens and intersection of these various federal regulatory programs," TMA and the others wrote. "We also urge CMS to use its discretionary authority provided by Congress under these programs to develop solutions for synchronizing these programs to minimize burdens to physician practices, and propose these solutions in the physician fee schedule proposed rule for calendar year 2013. The Department of Health and Human Services (HHS) recently announced its continued commitment to complying with President Obama's Jan. 18, 2011, executive order calling on federal agencies to reassess and streamline regulations. This is a perfect opportunity for HHS to make good on its commitment to improve the regulatory climate for physicians."
The letter added that HHS "has a responsibility to review all of these programs and take the opportunity to ease the burdens on physician practices." They also urged CMS to discontinue back-dating penalties in the programs and better synchronize the incentive and penalty programs so that physicians who successfully participate in one program are protected from penalties associated with the other programs.
Action, April 3, 2012