September 11, 2018

Tax Reform for Businesses: Tax Rates and AMT for C-Corporations

There has been a lot of buzz about tax reform changes and how they will affect companies in the coming tax years. Some of these changes include the reduction of the corporate and individual tax rates, the repeal of the corporate alternative minimum tax and higher individual alternative minimum tax exemptions for tax years beginning after December 31, 2017. Fiscal year corporations with tax years beginning on or before December 31, 2017 will have the benefit of a blended tax rate. Below we outline the previous law, what changed with the new law and how businesses will be impacted.

Previous Law

  • The corporate tax rate originally had a graduated structure with the lowest rate at 15% and the highest rate at 35%
  • The individual tax rate ranged from 10%-39.6% within seven tax brackets
  • Individuals and Corporations were subject to Alternative Minimum Tax (AMT), which is a second tax system. The taxpayer’s tax liability for the year was equal to the sum of the regular tax liability plus the AMT liability for the year

New Law

  • The corporate tax rate has been reduced down to a flat 21% for all C-Corporations
  • The new law includes seven individual tax brackets ranging from 10%-37% for various taxable income thresholds
  • AMT has been repealed for C-Corporations for tax years after December 31, 2017
  • AMT credit carryovers may still be used to offset tax, and 50% of the excess of the AMT credit over the tax liability will be refundable to taxpayers for any tax year beginning after 2017. This is allowed from 2018 through 2020, and any remaining credit carryover still existing in 2021 will be fully refunded.
  • After 2021, there will be no more AMT or AMT credits for corporations
  • Did not repeal the AMT for individuals, but increased the exemption amounts for tax years 2018-2025 making it less likely to hit AMT at lower income levels. The exemption amounts are $109,400 for married filing jointly and surviving spouses, $70,300 for single filers, and $54,700 for married filing separately

Impact on Businesses

Entity Structure Changes

With these changes to corporate tax, many business owners might start asking, “Should I form a C-corp now?”, but there are important things to consider. The earnings of C-corporations are taxed twice, once when the income is earned and again when the income has been distributed to the shareholders as dividends. Before making a decision, contact an Anders advisor to discuss your specific tax situation and see if an entity structure change would be beneficial for you.

Holding Real Estate in a C-Corp

Although the corporate tax rate has been reduced and the corporate AMT repealed, the same drawbacks still exist for holding real estate in a C-Corporation. As real estate appreciates in value and is sold, the gains are double taxed, and even with the lower tax rate in place and no AMT, this double taxation should be considered when considering a change of entity to hold real estate.

Contact an Anders advisor with questions on how these tax law changes will affect you, or learn more about tax reform changes in our Tax Reform Resource Center.

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May 4, 2018

Tax Reform: Impact on Health Care Organizations

The Tax Cuts and Jobs Act is changing the way organizations do business, including health care organizations. To help you prepare for the changes and take advantage of new benefits, the Anders Health Care Group has compiled a chart on the most important provisions for the industry.

Complete the form below to download the Tax Reform: Impact on Health Care Organizations chart.

Learn more about tax reform’s impact on individuals and other industries in the tax reform resource center.

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March 2, 2018

March 31 Upcoming Deadline for 2017 MIPS Reporting

The deadline to submit 2017 data for the Merit-based Incentive Payment System (MIPS) reporting is fast approaching. Clinicians participating in MIPS have until March 31, 2018 to submit evidence-based and practice-specific quality data to CMS. Find out if you’re eligible for MIPS.

Claims-based Quality measures for 2017 dates of service were due March 1 to the Medicare Administrative Contractor (MAC) for eligible clinicians. Claims-based reporting for Quality measures only applies at the individual reporting level as group reporting is available in alternative methods. Large groups reporting through the CMS Web Interface need to submit 2017 data by March 16.

MIPS Next Steps

Once all data is submitted to CMS, they will provide performance feedback between April 1 and December 31, 2018. Eligible clinicians and groups reporting will have an appeal opportunity to correct errors in CMS’ findings, if applicable. CMS will then begin applying payment adjustments, positive or negative, to each applicable claim starting January 1, 2019.

Individuals and groups can be successful participants in 2018 even if a plan is not yet in place or the practitioners are working from paper charts. The penalties and incentive payments increase yearly with 5% at stake for the 2018 performance period.  Contact an Anders advisor to learn how MIPS will affect your health care organization, or learn more about the Anders Health Care Group.

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January 9, 2018

How Hospitals Qualify for Not-for-Profit Tax-Exempt Status

To qualify as a not-for-profit, tax-exempt hospital, there are a number of requirements that must be followed under IRS section 501(c)(3). The Affordable Care Act added even more requirements through section 501(r), stating that hospitals must be able to show the benefit it brings to the community through a community health needs assessment.

Section 501(r) requires tax-exempt hospitals to satisfy the following requirements:

  • Conduct a community health needs assessment (CHNA) – A CHNA must be conducted every three years and include an implementation strategy to meet the community health needs listed in the assessment. This information must be publicly available.
  • Establish a financial assistance policy (FAP) – A written FAP must include
    • Eligibility criteria for financial assistance and free or discounted care
    • Basis for calculating amounts charged to patients
    • Method for applying for financial assistance
    • Actions the hospital may take in the event of non-payment
    • Measures to widely publicize the policy in the community served
  • Implement limitations on charges – The hospital must implement limits on charges for emergency or other medically necessary care provided to individuals eligible under its FAP. These limits cannot be more than those charged to patients with insurance.
  • Enforce a collection policy – The collection policy must require the hospital to make “reasonable efforts” to determine if the patient is eligible for financial assistance before taking “extraordinary collection actions”.

Not satisfying the above requirements provides grounds for the IRS to revoke the organization’s tax-exempt status under section 501(c)(3).  The IRS is currently auditing hospitals for compliance and has already revoked one organization’s tax-exempt status for not fully complying. For questions on how your organization can apply or comply to section 501(c)(3), contact an Anders advisor. Learn more about the Anders Health Care Group or Not-for-Profit Group.

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December 20, 2017

MIPS 2018: Virtual Groups for Solo or Small Practices

Medicare’s final rule provides a new opportunity for solo practitioners and small groups to join together and report as a virtual group.  For small groups interested, the deadline to elect a virtual group is December 31, 2017 for the upcoming 2018 performance period.

What is a Virtual Group?

Medicare defines a virtual group as a combination of two or more Taxpayer Identification Numbers (TINs), representing solo practitioners and groups of ten or fewer clinicians who come together “virtually”, regardless of specialty or location, to participate in MIPS for a performance period. Each TIN joining has at least one Merit-based Incentive Payment System (MIPS) eligible clinician. A solo practitioner or group can only participate in one virtual group per performance period, but there are no limits to the number of entities that form a virtual group.

Why Virtual Groups?

The addition of virtual groups in year two of MIPS extends some benefits to those practitioners who are included in the program but may not have the same technology and staff resources to be competitive. Achieving a high score in relation to others means receiving an incentive as opposed to a negative payment adjustment. Medicare provided assumptions in MACRA 2015 that noted solo and small groups were more likely to receive negative payment adjustments, while larger groups were more likely to receive positive payment adjustments. By allowing virtual groups, the thought is to give some benefits to the smaller classes.

How Does My Practice Qualify as a Virtual Group?

Because the groups are otherwise independent of each other, notification must be provided to Medicare before the December 31, 2017 deadline of the virtual group’s formation. Interested practitioners should review the full details and qualifications of the program. Medicare has assigned Quality Payment Program Technical Assistance organizations by state if practitioners need additional resources. Requirements include the following:

  • Formal written agreement between all members
  • Virtual group representative chosen who will submit the election via email to CMS at
  • Provide TIN and NPI associations for the group
  • CMS reviews the virtual group’s low-volume threshold by reviewing its claims. It also verifies group eligibility for the number of practitioner NPIs associated with the small group’s Taxpayer Identification Number. A TIN with the ten or fewer practitioners accepted into the virtual group by CMS will remain in the virtual group for the performance period even if the group’s size changes during that time

For help navigating the Quality Payment Program or forming a Virtual Group, contact the Anders Health Care Group.

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May 24, 2017

Determining MIPS Eligibility with the CMS Look-up Tool

Clinicians have been waiting to find out if they are eligible for the new Merit-Based Incentive Payment System (MIPS), and after continued delays, CMS is providing answers. CMS recently mailed letters to Medicare participants based on Tax Identification Number (TIN). The letter will identify clinicians based on their National Provider Identifier (NPI) linked to the TIN and if the clinician individually or the group TIN is exempt or included in MIPS. Letters are mailed to the TIN address on file with Medicare.

If You Have Not Received a Letter

For those who have not received a letter, a look-up tool is available from CMS, searching by individual provider’s NPI.  The look-up tool, similar to the letter, will note if Medicare has an individual linked to more than one organization TIN and the reporting requirement under each provider’s unique NPI/TIN combination. The look-up tool can be especially helpful to practice administrators or clinicians who did not personally view the letter mailed because it was received by administrative leaders or a corporate office.

Determining Eligibility

Keep in mind eligibility determination is based on a first review of Medicare’s claims records from its fiscal year closed August 31, 2016.  Below are reasons why a clinician may be deemed exempt from the 2017 transition year for MIPS:

  • First year for Medicare enrollment
  • Meeting the low-volume threshold
  • Qualified Participant in an Advanced APM

Clinicians with a notice of exemption from MIPS in 2017 will be exempt based on Medicare’s initial determination. A second review of claims data will occur for dates September 1, 2016 through August 31, 2017. Clinicians included in MIPS by the first determination period may be exempt in December 2017 if exclusions were met upon the second claims review.

Acronym legend
APM: Alternative Payment Model

CMS: Centers for Medicare and Medicaid Services
QPP: Quality Payment Program
MACRA: Medicare Access and CHIP Reauthorization Act of 2015
MIPS: Merit-based Incentive Payment System
NPI: National Provider Identifier
TIN: Tax Identification Number

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May 24, 2017

House Votes to Repeal Obamacare

The U.S. House of Representatives recently voted 216 to 211 to pass a bill to repeal and replace the Patient Protection and Affordable Care Act (ACA), also known as Obamacare.  As you might suspect, the votes predominantly followed party affiliations.  The new American Health Care Act (AHCA) bill previously received the backing of the House Freedom Caucus on April 26th, which opposed the previous version of this bill.  Although the Congressional Budget Office (CBO) has not separately scored this version of the bill, it has stated that the bill would leave the same number of individuals without insurance as the original bill – 24 million individuals.

Some of the highlights of this bill include:

  1. Eliminate the individual mandate
  2. Medicaid expansion is rescinded and replaced with block grants
  3. The amount insurers may charge an individual based on their age for insurance has increased from 3:1 to 5:1
  4. Various taxes are eliminated including excise taxes, medical device taxes, etc.

The next step in the process is the U.S. Senate will consider the AHCA House bill.  At this point, several organizations oppose this bill and it is not expected to pass the Senate vote, but we will provide updates. Contact the Anders Health Care Group with questions on how the proposed bill could affect your organization.

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April 14, 2017

Rural Health Clinics Services Sheet

Now more than ever, health care today is a balancing act. It’s about employees, technology, reimbursements, regulations, reform – and of course, patient care. Our comprehensive view of the health care industry recognizes how everything you do in your organization impacts your bottom line.

Whether you’re a physician or a CFO or a practice administrator, the team at Anders will give you the vision and direction to make sense of your finances and operations, and free you to focus on your patients.

Just as things in this industry are always changing, we’ll always be right by your side to answer your questions and help drive smart, informed decisions. You’ll have direct access to our health care leaders and our entire team of industry and advisors.

We offer extensive, multidisciplinary financial and advisory services for physicians, hospitals, medical centers, home health organizations, nursing homes and other facilities, from individual practices to multi-location health systems.

Our advisors bring a strong combination of financial, operational and strategic expertise to help you succeed.

We offer the following services for rural health clinics:

  • Annual Evaluation
  • Cost Reports
  • Mock Survey
  • Operational and Workflow Assessments
  • Revenue Cycle Acceleration
  • Feasibility Study
  • Practice Manager Training
  • Interim Management
  • Provider Compensation Modeling

How Can We Help Your Clinic Grow?

Revenue Cycle Acceleration and Technology Utilization

  • Revenue Cycle Assessment and Process Improvements
  • Value-Based Payment Transition Assistance
  • Policy Development and Implementation
  • Fraud Prevention and Detection
  • Fee Schedule Analysis and Development
  • Managed Care Contracting
  • Contract Renegotiations
  • Benchmarking and Financial Analysis
  • Billing Service Oversight
  • Interim and Long-Term Revenue Cycle Management

Credentialing and Enrollment

  • Medicare PECOS and CAQH
  • Hospital Affiliations
  • Provider Portal Repository Software
  • Payer Enrollments
  • Insurance Revalidation

Technology Optimization

  • EHR/PMS Assessment, Purchase, & Implementation
  • System Optimization
  • NextGen Certified Training
  • Software Hosting
  • Infrastructure Architecture & Ongoing Maintenance
  • CIO Strategic Services
  • HIPAA Security Risk Analysis Compliance and Patient-Centered Care
  • Customer Service Training
  • Patient Experience Enhancement
  • Workflow Assessments and Redesign
  • HIPAA Compliance
  • OSHA Compliance
  • HR Policies and Procedures

Strategic Positioning

  • Rightsizing Strategy & Implementation
  • Sustainable Compensation Models that Incentivize
  • Service Line Development
  • Start-up of Medical Practices and other Entrepreneurial Ventures
  • Buy-Sell-Merge-Expand Decision Propositions
  • Practice Valuation
  • Interim Management

Physician-Hospital Relations

  • Employment Arrangement Strategies
  • Compensation Model Development
  • Fair Market Value Compensation Opinions
  • Clinical Care Coordination

Comprehensive Accounting

  • QuickBooks® Consulting
  • Accounting System Consultation, Implementation and Training
  • Financial Statement Analysis and Preparation
  • Payroll Preparation and Tax Reporting
  • Sales and Use Tax-Related Consulting
  • Employee Benefit Plan Administration
  • Business Plan Development

Tax Planning and Compliance

  • Strategic Tax Forecasts
  • Comprehensive Business-Personal Services
  • Fraud Prevention and Detection
  • Managed Care Contracting to Optimize Opportunities

To learn more about our Health Care Group or arrange a meeting with our team, please contact: Brian M. McCook, CPA, 314-655-5564,

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February 21, 2017

MACRA Quality Payment Program Guide

The Medicare Access & CHIP Reauthorization Act of 2015 (MACRA) is a Quality Payment Program that will affect how clinicians are reimbursed for Part B Medicare claims, starting in 2019.

Most clinicians will fall under the Merit-based Incentive Payment System (MIPS), and earn a payment adjustment, positive or negative, based on evidence-based and practice specialty quality data.

Payments will be impacted in 2019, based on 2017 performance, starting at 4% and increasing yearly.

Data must be collected in 2017 on chosen performance measures and submitted to the Centers for Medicare & Medicaid Services (CMS) to avoid a 4% penalty.

How Adjustments Will Be Determined

The MACRA Quality Payment Program is budget neutral for Medicare dollars, meaning eligible clinicians are competing to be top performers. Data submitted each year will be analyzed and a composite score will be calculated. Based on the composite score, clinicians above average will earn a positive adjustment and those below will receive a penalty, up to the maximum adjustment assigned for that year.

While employed professionals may have some protection in their salary contract initially, formulas for compensation are expected to change from heavy reliance on Relative Value Units (RVU) to quality-based factors.

Who is Affected

  • Medical Doctors
  • Doctors of Osteopathy
  • Doctors of Podiatric Medicine
  • Doctors of Dental Surgery/Medicine
  • Doctors of Optometry
  • Chiropractors
  • Nurse Practitioners
  • Clinical Nurse Specialists
  • Certified Registered Nurse Anesthetists
  • Physician Assistants

In 2019, Medicare has proposed to add more clinical professions such as physical therapists, clinical social workers and more.

Engage for Bonuses

Clinicians strategically prepared for MIPS and achieving exceptional results will be rewarded with an additional bonus in addition to their positive payment adjustment.

The Anders Health Care Group is prepared to assist your health care organization in transitioning into the first year of the program. To learn more about Anders Health Care Group or arrange a meeting with our team, please contact and Anders advisor.

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September 14, 2016

Closing the Documentation Gaps in Your EHR

Documenting accurate health care data is important to both practitioners and patients, because as we’ve all heard, “if it isn’t documented it isn’t done”. Reimbursement regulations require correlating notes to billed services, and patients expect accurate, compiled health records. Certified Electronic Health Record (EHR) systems are designed to record and track accurate documentation for exchange with other health care facilities or to be accessible in the patient’s portal.

Checking for Documentation Gaps in your EHR
To maximize the potential of an EHR and patient safety, it’s important to ensure there are no documentation gaps, and that what is captured in the EHR is consistent with the document produced. To avoid being caught with vital, trapped data in the chart, we recommend performing a documentation gap analysis.

Start by selecting a variety of visit types including a sampling of procedures.  Follow all EHR screens, taking a screen shot if possible.  Generate the final document and compare it to the data entered.  Are there gaps?

Documentation gaps may be intentional or unintentional. Some intentional examples include:

  • Practitioner’s personal use: This could serve as a personal reminder for subsequent visits, not intended for inclusion to a chart note.
  • Alert: This may be used for a variety of reasons including non-compliance such as drug-seeking behavior. It could be a safety alert such as recognizing the patient is a fall risk.
  • Not pertinent to current service: Some structured data may be eligible for compilation to a visit or procedure note, but the clinician deems it is not relevant to the current note, awaiting the appropriate reason for visit to incorporate that table or information to the note.

Unintentional examples can come from multiple areas within the EHR, which is why we suggest sampling a variety of visit types.  With the adoption of EHRs, the resulting document can compile so much data that a one page SOAP note is now six pages, including a variety of demographic and historical information not necessarily reviewed by the provider generating the final document.  The practitioner may not recognize items missing.  Data unintentionally left out of the EHR-generated document may include the following:

    • Marked boxes for findings
    • Free-text boxes
    • Pop-up template items
    • User Error – For example, the EHR may have a check box to include a section to the final note. Missing the checkbox means it is not pulled to the document.

Closing the Gaps
Create a listing of the EHR documentation gaps, mapping to specific sections in the EHR and where the documentation should be placed within the visit note.  Check with the EHR vendor or company if gaps found are “known issues,” and what update or fixes are available.  Representatives from the clinical team, such as the Medical Assistant, Nurse, and Practitioner should review the findings as a group, possibly with an EHR super-user From the analysis, the clinical team can recognize and prioritize the gaps that need addressed, and conduct further testing if needed. Alert the entire clinical team to gaps discovered and the work around.

Contact an Anders advisor to learn more about closing the gaps in your EHR.

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