CMS Issues Medicare EHR Incentive Checks

Beginning this week, CMS will begin issuing Medicare EHR Incentive Payments to those providers who have successfully attested to meeting meaningful use.  Eligible Professionals who have met the meaningful use requirements can expect payment of $18,000.  (Note, Eligible Professionals that have not yet met the $24,000 Medicare allowed charges threshold will not receive a check until that threshold is met).  Eligible Hospitals that have attested to meaningful use can also begin to expect their incentive payments.

CMS will issue incentive payments in the same manner as providers receive payments for Medicare services, via electronic funds transfer or check. Payments will be made to the TIN selected during registration for the Medicare EHR Incentive Program.

For those providers who have not yet registered for the EHR Incentive Program there is still plenty of time in 2011 to do so.  The Medicaid EHR Incentive Programs have launched in some states, with other expecting to launch later this Summer.

For assistance with registering for the Medicare EHR Incentive Program or understanding meaningful use please contact Elana Zana.

Attestation for EHR Incentive Programs Available

Earlier this month, CMS launched the attestation portion of the EHR Incentive Payment Program.  Beginning on April 18th, eligible professionals and hospitals are now able to attest to meaningful use (or adopt, implement or upgrade for Medicaid).  Along with the attestation itself, CMS launched its Meaningful Use Attestation Calculator, a wizard which walks eligible professionals and hospitals through the meaningful use objectives and enables the entity to determine if it can successfully meet the meaningful use standards prior to filling out the registration form. 

For those providers that are able to begin the registration and attestation process, access to registration and attestation is available here.  The CMS website also has a user guide that is helpful when registering as well as FAQs.  To be eligible for either the Medicare or Medicaid EHR Incentive Programs an eligible professional or hospital must be using certified EHR technology.  The ONC provides a list of which EHR systems are “certified.”

In addition, CMS is offering teleconferences regarding registration and attestation:

  • Tuesday, May 3, 2:00 – 3:30 p.m. ETRegister to join this call if you are an eligible hospital or CAH who wants to learn more about the attestation process for the Medicare EHR Incentive Program.
  • Thursday, May 5, 1:30 – 3:00 p.m. ET- Register to join this call if you are an EP who wants to learn more about the attestation process for the Medicare EHR Incentive Program.

Some states are also offering webinars about the Medicaid EHR Incentive Payment Program and how to register.  Registration for the Medicaid EHR Incentive Program requires both registration with CMS and on the state level.  However, eligible professionals and hospitals will not be able to register with CMS for the Medicaid EHR Incentive Program until their state is ready to start its Medicaid EHR Incentive Program.  Washington expects to go-live in June 2010; California plans to go-live this Summer for eligible professionals. 

If you have questions regarding the Medicare or Medicaid EHR Incentive Programs or would like some assistance with understanding meaningful use or calculating patient volume (Medicaid) please contact Elana Zana or Dave Schoolcraft.

Washington Announces Medicaid EHR Incentive Program Training Webinars

Yesterday, Washington State announced upcoming training webinars for the Medicaid EHR Incentive Programs.  These webinars are designed to help hospitals and eligible professionals prepare for their participation in the Medicaid EHR Incentive Programs.  Washington anticipates rolling out the Medicaid EHR Incentive Program in June. 

Program Planning & Implementation Update (WSHA specific)

Wed., March 23

10-11 AM

https://www2.gotomeeting.com/register/638732130

Program Planning & Implementation Update

Wed., April 13th

10-11 AM

https://www2.gotomeeting.com/register/727138786

Qualifying For Incentives & Meeting Required Patient Volume Thresholds  

Wed., April 27th

10-11 AM

https://www2.gotomeeting.com/register/212646515

Overview Of Adopting, Implementing & Upgrading EHR Systems (AIU) & Meaningful Use

Wed., May 11th

10-11 AM

https://www2.gotomeeting.com/register/183445538

Registering for the Medicaid EHR Incentive Program

Wed., May 25th

10-11 AM

https://www2.gotomeeting.com/register/332772211 

Incentive Payments & Reassignment Process

Wed., June 8th

10-11 AM

https://www2.gotomeeting.com/register/518246379 

Attestation & the Audit Trail

Wed., June 22nd

10-11 AM

https://www2.gotomeeting.com/register/592783331

For more information regarding the Washington Medicaid EHR Incentive Program click here.

Medicaid providers are eligible for up to $63,750 in Incentive Payments over the six years of the program.  If you would like more information about determining your hospital’s or practice’s eligibility, meaningful use, or calculating your estimated incentive payments please contact Elana Zana.

Modification in Medicaid EHR Incentive Program Calculation – Net Average Allowable Cost

In December 2010, Congress passed the Medicare and Medicaid Extenders Act of 2010.  Along with a variety of other changes, Congress modified one of the inputs in calculating the incentive amount under the Medicaid EHR Incentive Program, specifically the Net Average Allowable Cost calculation.

In the original enactment of the ARRA, the Medicaid EHR Incentive Payments were based on a formula which required that the Secretary of HHS determine the average allowable cost for certified EHR technology, and allow eligible professionals to collect incentive payments in an amount not to exceed 85% of the net average allowable cost, or $21,250 (in the first year or $8,500 in subsequent years) whichever amount is smaller.  Determining the net average allowable cost, per the HHS Final Rule, was not an easy feat.  HHS determined that the average allowable cost for certified EHR technology for the first year was $54,000 and therefore a provider was allowed to collect up to $29,000 of cash gifts towards the certified EHR technology without seeing a reduction in their EHR Incentive Payment.  The Net Average Allowable Cost was calculated as follows:

 1st Year Incentive = ($54,000 – cash gift for EHR) * 85% or $21,250 (whichever is smaller)

2nd-6th Year Incentive = ($20,610 – cash gift for EHR) * 85% or $8,500 (whichever is smaller)

Providers were also responsible for showing that they have contributed at least 15% of the net average allowable cost to the purchase or utilization of certified EHR technology.  The Final Rule created a detailed description of what items may be included and excluded from the 15% calculation, as well as any gifts for EHR technology. 

 Congress has since changed these complicated calculations, making it easier on eligible professionals. 

The new change recently passed by Congress relating to the incentive calculation is the assumption that the provider has expended at least 15% of the net average allowable cost provided that the EHR Incentive Payment to the provider is not in excess of the 85% of the net average allowable cost.  In other words, Congress will now assume that as long as the Medicaid EHR Incentive Payment does not exceed $21,250 in the first year and $8,500 thereafter, the eligible professional is assumed to have paid the remaining 15% and is therefore eligible for the entire Medicaid EHR Incentive amount.

These changes are still subject to HHS releasing new rules interpreting Congress’s enactment and accordingly modifying the Final Rule issued this summer.  However, in light of Congress’s intent it appears that the change will ease the confusion on how to compute the net average allowable cost and to determine whether a Medicaid provider has adequately paid for certified EHR technology.

Registration for Medicare EHR Incentive Payments Starts January 3rd

Starting on January 3rd, 2011, registration for the HITECH Electronic Health Record Medicare Incentive Payments will open.  This registration is available for both eligible professionals and eligible hospitals, including Critical Access Hospitals.  The registration link will be available starting on January 3rd and can be accessed here.  Registration for the Medicaid EHR Incentive Payments will be available for the following states:  Alaska, Iowa, Kentucky, Louisiana, Oklahoma, Michigan, Mississippi, North Carolina, South Carolina, Tennessee, and Texas.  In February, registration will likely open in California, Missouri, and North Dakota.  It is anticipated that other states, including Washington, will  launch their Medicaid EHR Incentive Programs during the spring and summer of 2011.

For mor information regarding the Medicare Incentive Payments see the CMS press release.  For a general overview of the HITECH incentive payments please read our previous blog posts for physicians and hospitals.  As a disclaimer, these blog posts were written prior to the issuance of the Final Rules but provide a good overview of the statutory requirements.

CMS has also issued tip sheet regarding Stage 1 Meaningful Use for hospitals, and Critical Access Hospitals, click here to access the tip sheet.  The tip sheet for eligible professionals can be accessed here.  Additional information may be obtained by contacting CMS or your State directly (CMS and State Medicaid Contact List & Information).

If you would like further information regarding achieving Meaningful Use, registering for the Medicare Incentive Payments, or assistance calculating the Medicare or Medicaid incentive payments please contact Dave Schoolcraft or Elana Zana.

Initial Certification of EHR Technology

The Drummond Group and CCHIT announced this week the certification of EHR technology.  CCHIT certified 33 complete EHRs and modules, click here to access the list.  The Drummond Group certified 3 complete EHRs and modules, click here to access the list.  The certification of these EHRs is significant because meaningfully using certified EHR technology  is required to qualify for the Medicare and Medicaid incentive payments.  Hospitals and eligible providers may use either a complete EHR system to show meaningful use or a set of modules that combine create a complete EHR system.

For more information regarding meaningful use and certification visit the ONC FAQ page.

Critical Access Hospital Incentive Payments

CMS has issued a Critical Access Hospital (CAH) Tip Sheet to assist CAH’s in evaluating eligibility under the Medicare EHR Incentive Payment program.  Though, CAH’s are now eligible for Medicaid EHR Incentive Payments, this eligibility is similar to all other acute care hospitals.  CAH’s are not entitled to a different calculation formula for Medicaid EHR Incentive Payments.   

To view the Medicare CAH Tip Sheet click here.

To view the Medicaid Tip Sheet for Acute Care Hospitals click here.

If you have questions or need assistance in calculating the estimated Medicare or Medicaid Incentive Payments for your hospital or with achieving meaningful use please contact Elana Zana.

CMS Launches EHR Incentive Payment Website

To help answer questions regarding meaningful use and the EHR incentive payments, CMS has launched an EHR Incentive Program website.  The website provides FAQ’s, CMS presentations, fact sheets, and more.  To view the site click here.

CMS Presentation on Meaningful Use & EHR Incentives Final Rules

On July 13, CMS issued the Medicare and Medicaid Programs Electronic Health Record Incentive Program Final Rules.  These final rules were published in the Federal Register on July 28th. 

On July 22nd, CMS hosted a conference call to explain the changes in the Final Rules as compared to the Proposed Rules.  Some key changes include:

  • Inclusion of Critical Access Hospitals in the definition of eligible hospital for Medicaid incentives.
  • A revised definition of hospital based eligible professionals to exclude only those physicians that provide 90% or more of their services in either an inpatient or emergency department.
  • Eligible Professionals and Eligible Hospitals may defer 5 optional “menu set” Meaningful Use reporting objectives.
  • Reduction in measure thresholds for Meaningful Use reporting objectives.

To view the CMS slide presentation click here.  ONC has also published a slide deck entitled “Supporting Meaningful Use” that provides helpful guidance.  CMS has also launched an EHR Incentives website which has fact sheets, press releases, general information, and instructions on how to participate, also on the website will be the transcript of the CMS conference call.

In addition, CMS has published the Health Information Technology: Initial Set of Standards, Implementation Specifications, and Certification Criteria for EHR Technology.  For more information on these Standards click here.

If you have questions regarding how these final rules will affect your practice please contact Elana Zana.

249 Members of Congress Urge CMS to Revise Meaningful Use and Incentive Eligibility

In a letter submitted to CMS on March 15th, Members of Congress encouraged CMS to revise its proposed definition of meaningful use and the restrictions on the EHR incentive payments.  The letter covered three topics:

1) the definition of Meaningful Use;

2) the definition of Hospital-Based Physician; and

3) the limitation on payments to Multi-Campus hospitals.

Specifically, the letter discussed the application of the meaningful use requirements for both Medicare and Medicaid and urged CMS to relax the restrictions and the broad scope of the definition.  The letter recommends that CMS modify the hospital-based definition to allow incentive payments for physicians that furnish services in hospital-owned ambulatory settings by excluding those physicians from the definition of hospital-based.  Lastly, the letter requests that CMS identify hospitals as discrete facilities regardless of whether the hospital is part of a multi-hospital system operating under the same Medicare provider number.