We previously reported that providers that bill Medicare Part B for services outside the FQHC service package will be subject to the PQRS penalties, however, last week, CMS put out further clarification on this issue that we wanted to make you aware of.

In a recent MLN Matters article, CMS clarified that the PQRS penalties do not apply to those providers who ONLY provide Medicare Part B services at FQHCs or RHCs.  However, if a provider provides Part B services at an FQHC or RHC and a non-FQHC/RHC setting, the PQRS penalties do apply.

Please note, the Medicare FQHC PPS payment (or all inclusive rate, if your center has not yet transitioned to the PPS) is not billed on the Part B fee schedule.  This would apply only to those services provided outside of the FQHC benefit. 

FAQs from CMS MLN Matters Article

Question:
If I furnish professional Medicare Part B services only at an RHC or an FQHC, are the services eligible for PQRS?

Answer:
No, if you furnish Medicare Part B professional services only at an RHC or an FQHC, such services are not eligible for either the PQRS incentive payment or for the PQRS negative payment adjustment.

Question:
I’m an Eligible Professional (EP) and I furnish professional Medicare Part B services at an RHC/FQHC and also furnish services at a non-RHC/FQHC setting. Are the non-RHC/FQHC services eligible for the 2015 PQRS incentive payment or for the PQRS negative payment adjustment?

Answer:
Yes, for an EP who furnishes professional Medicare Part B services at an RHC/FQHC and also furnishes services at a non-RHC/FQHC setting, the non-RHC/FQHC services may be eligible for the PQRS incentive payment or the negative payment adjustment. The PQRS program applies a negative payment adjustment to practices with EPs, identified on claims by their individual National Provider Identifier (NPI) and Tax Identification Number (TIN), or group practices participating via the Group Practice Reporting Option (GPRO) (referred to as PQRS group practices) who do not satisfactorily report data on quality measures for covered Medicare Physician Fee Schedule services furnished to Medicare Part B Fee-For-Service beneficiaries. A negative payment adjustment may be triggered in future year(s) if an EP furnishes services, but does not report them.

You can read the MLN Matters article here, and NACHC’s previous blog post on this topic here.