We have not yet finalized our proposals with respect to overpayments under Medicare Parts A and B in the December 2022 Overpayment Proposed Rule
Step 3Determine per capita amount of improper payments attributable to the relevant population: Determine the per capita amount of improper payments for the performance year or benchmark year included in the per capita Medicare Parts A and B FFS expenditure amount for a population identified in Step 2 (as proposed in 425.674(c)(3))
In addition, because reconciling a rebate amount imposes substantial administrative burden on CMS to reprocess the rebate amount, retest the reporting system, and reissue a Rebate Report, CMS proposes in 428.401(d)(2) that it may exercise discretion not to initiate recalculation of the rebate amount in these situations which are outside of the regular reconciliation process proposed in 428.401(d)(1)
Therefore, accepting an incomplete data submission for the Promoting Interoperability performance category would be counterintuitive to a MIPS eligible clinician demonstrating whether they are a meaningful user of CEHRT in accordance with sections 1848(q)(2)(A)(iv), (B)(iv) and 1848(o)(2)(A) of the Act
These players collectively account for a substantial portion of the national market
We still dont anticipate StreamlineMD systems to be fully operational before 12:00 pm EST on Friday, September 26, 2025
