Higher payment made under the requirements of the regulation is for physicians reimbursed pursuant to a physician fee schedule. Physicians working in a clinic and reimbursed through a physician fee schedule could qualify for higher payments if they are appropriately Board certified or if 60 percent of the services that he or she provides is for the specified primary care services. Since the clinic itself is not eligible, this percentage of services threshold cannot be based on the aggregate of all services provided by all practitioners within the facility, only on services the individual physicians.
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94171
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Community clinics in my state (clinics other than Federally Qualified Health Center and Rural Health Clinic are reimbursed at the same rate as a physician. They do not receive a bundled or encounter rate. Are they eligible for the higher payment under CMS 2370-F? Would they have to attest that 60 percent of the services provided in the clinic are within the qualifying Evaluation & Management (E&M) codes? Are they required to pass through any increased payments in the form of higher wages for the health care professionals they employ?