For providers who are required to participate in the federal government's Quality Payment Program, the exemption application is open for the 2023 reporting year. The government is allowing COVID-19 to be the basis for the exemption. Why bother? If you are required to participate in the program based on your Medicare volume, you must either report or apply for the exemption to avoid the 9% penalty on all Medicare reimbursement in 2025. To double check on your participation requirement, go to https://qpp.cms.gov/ and enter your National Provider Identifier (NPI).
To determine if your 2023 Medicare payments are being penalized for Performance Year 2021, ask your billing team to print off a Medicare remittance. If you see the remark code, CARC 237, you are currently being penalized for failure to successfully participate in the QPP - or declare an exemption. (Claims adjustment reason code 237 is used to denote “Legislated/Regulatory Penalty.")
To apply for the exemption, go to: https://qpp.cms.gov/mips/exception-applications. The application deadline for 2023 is 8 p.m. EST on January 2, 2024. The application takes minutes and can save you tens of thousands of dollars in penalties. If you change your mind and decide to report on the appropriate measures, your application is voided. There is no downside to applying, so don't delay.
The contents of The Sentinel are intended for educational/informational purposes only and do not constitute legal advice. Policyholders are urged to consult with their personal attorney for legal advice, as specific legal requirements may vary from state to state and/or change over time.
