Why some docs are sitting out the EHR incentive program this year
Still trying to decide whether to pursue the meaningful use incentives in 2011? In an FPM opinion piece titled "The EHR Incentive Program: Consider Waiting for Next Year," David Kibbe, MD, explains why "prudent physicians and health care organizations across the country are sitting out meaningful use for 2011." He argues that certified EHR systems may become more affordable and the incentive program itself may become simpler.
What do you think? Have you already gone through the attestation process and received your first check? Or are you sitting it out this year? Read Dr. Kibbe's assessment, and post a comment below or send it to firstname.lastname@example.org.
The check's in the mail … for real this time
Reports have been coming in that the first round of incentive payments for meaningful use have been delivered.1,2 This is more evidence that the Meaningful Use incentive program will operate more efficiently than the Physician Quality Reporting Initiative (PQRI) program.
Unfortunately, we do not have data on how many eligible providers attested and how many of those qualified. As the program participation increases, we will need to see how CMS scales to meet the demand. Currently CMS is telling providers that payments should be seen in four to eight weeks after attestation is completed – if the provider qualifies.
Does the fact that payments have been made in the program give you more confidence that your check will be in the mail?
Steven E. Waldren, MD
Another milestone for the EHR incentive program
On April 18, 2011, the Medicare EHR Incentive Program check-cashing window will be open for business. "Eligible professionals" who have registered for the program and followed the letter of the law as "meaningful users" of "certified EHR technology" for 90 consecutive days in 2011 will be able to log on to the CMS attestation web site and stake their claim to up to $18,000 in bonus cash. You’ll need to provide more than your signature, but not as much as your first born, as you navigate this fledgling process and enter an array of data elements from your ONC-ATCB-certified EHR system. EHR vendors and certifiers have led us to believe that extracting that data will be practically automatic, though I fear for many it will be more like extracting wisdom teeth … with a plastic spork. It is easy to be a skeptic in uncharted territory, and I deeply respect those pioneers who are not afraid to blaze a trail and prove the path for the rest of us. I believe that meaningful use could be a path to a better life for physicians and their patients in a transformed health care system, and though the theory is sound enough, the implementation is ever mirky. It is still far too early to see the proof in the pudding, but on April 18 we will reach another milestone to meaningful use that will assure us of our path … or provide us with even more to give CMS grief about.
FAQ: What data do I need to submit for the EHR incentives?
To be eligible for the electronic health record system (EHR) incentive payments for 2011 and 2012, you will have to report data for all of your patients (not just Medicare or Medicaid patients) on six measures:
• Three core quality measures: blood-pressure level, tobacco status and adult weight screening and follow-up. (If any of these do not apply, the following alternates may be used: influenza immunizations for patients older than 50, weight assessment and counseling for children and adolescents, and childhood immunizations.)
• Three clinical quality measures chosen from 44 National Quality Forum
and/or Physician Quality Reporting Initiative (PQRI) measures.
Note that in your first payment year, you can report data for a
90-day period and still receive the maximum incentive from Medicare for the year. Medicaid eligible providers (those whose caseloads include at least 30 percent Medicaid patients) can receive payment in their first year without reporting on any measures. This is due to the “adopt,
implement, upgrade” clause from the HITECH Act.
For 2011, you will have to manually submit your data using a web-based system managed by the Centers for Medicare & Medicaid Services (CMS) and attest that these numbers were arrived at using certified EHR technology. In later phases, EHR systems will likely be able to send the results to CMS electronically.
If you are even considering qualifying for these incentives, get registered now.
First step toward getting the EHR incentives: Registration
I have often thought that presentations (or blogs) that begin with the definition of a word are poorly conceived (and after reading this one, you might agree). But after looking up the word "register," in conjunction with the introduction of the online opportunity for eligible professionals to sign up for EHR incentives through the Centers for Medicare & Medicaid Services (CMS), I just couldn’t help myself. "Register - A grille for admitting heated air."
"That’s not what CMS is talking about when they refer to 'registration' for the EHR incentive programs," you say. Well they might want to expand their expectations because they will indeed find themselves in a position of receiving a lot of heated air from eligible professionals who are frustrated with the implementation of this component of the HITECH legislation and its descendant regulations.
"Meaningful use of certified EHR technology" has become a powerful concept in the realm of U.S. health care. With $30-$50 billion in taxpayer money directed into this initiative, it’s hard to be practicing medicine and not be aware of the financial incentives promised by CMS for becoming a "meaningful user." With incentive programs through Medicare and Medicaid, this is money that you need to think twice about leaving on the table. The first step toward getting your hands on that money … registration.
Apparently, it takes "10" to register. But whether that is 10 minutes or 10 hours seems to be a point of contention. One family physician has reported that he had to contact a representative of the U.S. Congress to get the information needed to register. Another watched an instructional video on the process by family physician Tripp Bradd, MD, and was done in a snap. Your mileage may vary significantly. The take home message: Don’t wait until the last 10 minutes to begin this process if you intend to qualify as a meaningful user in 2011. Stories of dealing with the bureaucracy of CMS are epic. If your registration or subsequent attestation for the CMS EHR incentive does not go perfectly, resolution of your issue may take days, weeks, even months to move through the required channels. Get registered ASAP if you are even considering qualifying for the CMS EHR incentive in 2011.
Much of the difficulty with registration relates to username and password issues linked to PECOS (Provider Enrollment, Chain, and Ownership System) and NPPES (National Plan and Provider Enumeration System). That information can be difficult to track down, though CMS has made online look-ups available, which work for some. For others, however, tracking down, resetting or creating those credentials has been a nightmare. The time spent on hold with CMS can be worse than trying to make an appointment at your office. Use the online tools if you can (and get online tools for your patients to make appointments).
Another issue interfering with successful registration is entering a valid EHR certification ID. The required "CMS EHR Certification ID" is not the same as the "ONC EHR Certification ID" that has been associated with most EHR products, whether "complete" or "modular." The registrant must use online tools from another site to calculate the needed number based on the suite of ONC-ATCB certified products they are using to achieve meaningful use. (Read these step-by-step instructions.) A suggestion to CMS: Let us enter the individual ONC EHR Certification IDs and you figure out (and let us know in real time) if the combination meets the full EHR certification requirements for meaningful use. I realize that CMS staff can't stand on a street corner and give this money away, but the harder they make the bureaucratic elements of this process, the fewer of us will actually adopt and use EHR technology in ways that will improve the quality, safety and efficiency of the care we provide.
That's all of my "heated air" for this time.
– Jason Mitchell, MD
FAQs about the EHR incentive program: tax consequences
Q: Will the EHR incentive payments be taxable?
A: Yes, the IRS will view all payments that you receive under the health IT incentive programs -- as much as $44,000 from Medicare or $63,750 from Medicaid -- as taxable income.
You may be able to write off a portion of the hardware or software purchase costs associated with your EHR, but there are limitations, so consult your tax adviser. Your tax adviser may also be aware of additional tax incentives unique to your state.
Got a question? E-mail us or post a comment below.
FAQs about the EHR incentive program: incentive checks
Q: I've heard that the EHR incentive payments will be sent to the individual physician, not to the practice. As the owner of a practice with four physician employees, I would expect to receive that money because I purchased the EHR. Could you clarify?
A: Our understanding is that the Medicare and Medicaid EHR incentive payments will be directed to the TIN (tax identification number) that an individual physician designates. The individual physician will need to qualify, apply for and attest to his or her "meaningful use" status. Details on the application and registration process should be posted soon on the CMS web site.
If the physician's employment contract specifies that Medicare payments go to the employer, the same should apply to the incentive checks. If the employer bought the EHR, then the employer should have the incentive check reassigned to the practice by the employee. The CMS web site supports this: "... under Medicare, eligible professionals (EPs) may choose to assign their incentive payments to their employer or entity with which the EP has a contractual arrangement. Under Medicaid, EPs also can choose to assign their incentive payments to their employer or to other state-designated entities."
Got a question? E-mail us or post a comment below.
Medicaid or Medicare Incentive - Which one should I choose?
The short answer is easy: Medicaid. The correct answer is not quite as easy, but it boils down to whether you are eligible for the Medicaid EHR incentive. The maximum Medicaid incentive is $63,750 compared with the $44,000 maximum for Medicare. Under the Medicaid incentive, you do not have to achieve meaningful use in the first year of the program, and you would receive $21,250 that first year. (You would have to prove meaningful use to receive any further payments, however.)
So how do you know if you are eligible?
You must have a patient volume of over 30 percent Medicaid in your practice. There are two definitions of "having 30 percent Medicaid." The first is based the number of encounters. For any 90 day period in the prior year, if more than 30 percent of your encounters were Medicaid encounters, then you are eligible. A "Medicaid encounter" is one in which Medicaid paid part or all of the service. The second definition, for providers seeing Medicaid managed care patients, is a little more complicated. The calculation takes into account both the percentage of your patients who are assigned to you under Medicaid and the number of Medicaid encounters you had with patients not assigned to you, called unduplicated Medicaid encounters.
The rule says that, in determining the number of Medicaid patients assigned to you during the "representative, continuous 90-day period," you should count those with whom you had Medicaid encounters earlier in the same calendar year if you have no other means of establishing that they were "current Medicaid patients." Once you've done that, the formula becomes this:
[(Number of Medicaid patients assigned + number of encounters with Medicaid patients not assigned to you) / (Total number of patients assigned to you + total number of encounters with patients not assigned to you)] * 100
If you meet the over-30-percent threshold for Medicaid patient volume, then it makes sense to participate in the Medicaid EHR incentive program as opposed to the Medicare EHR incentive program. However, in dealing with the government and/or money, there is always fine print, and here is one issue you need to pay particular attention to. Each state has the ability to modify the requirements for the Medicaid EHR incentive program. Check with your local Medicaid office or your Regional Health IT Extension Center, to see if your state plans to modify the requirements and how this might affect your eligibility.
If you have additional questions, use the "comments" link below to ask them.
Allow me to introduce this new blog and those who will be writing it.
The What. By the title, you can probably deduce that we will be blogging about Meaningful Use. Meaningful Use is a concept that was given life in the American Recovery and Reinvestment Act of 2009 (ARRA) or the so-called ‘stimulus package.’ This set of laws provides authority to the Centers for Medicare and Medicaid Services (CMS) to give eligible professionals (e.g. physicians) incentive payments for achieving meaningful use of certified EHR technology. These incentives can amount to $44,000 or $63,250 over 5 or 6 years for Medicare or Medicaid providers respectively.
More background information on meaningful use is available in a couple of recent AAFP News Now (ANN) articles:
- Agencies Issue Final Rules that Define, Support ‘Meaningful Use’ of EHRs
- AAFP’s Center for Health IT Weighs Burden of Meaningful Use
I would also encourage you to read the Family Practice Management article by David Kibbe, MD, titled A Physician’s Guide to the Medicare and Medicaid EHR Incentive Programs: The Basics.
The Why. The CMS incentive program will extend over several years and will have many moving parts. In addition to comprehensive articles and web stories, I feel that physicians and their staffs need relevant, timely, small chunks of information on meaningful use and the incentives. A blog provides a great solution for just that. I would also value an ongoing dialogue through comments, to help discover, explore and clarify information desired by family physicians and their primary care colleagues. (AAFP members may leave comments by clicking on the "Comments" link at the bottom of each blog entry and logging into the AAFP web site.)
Meaningful use is a stepping-stone to a broader and more valuable use of health IT in support of the transition to the patient centered medical home (PCMH) model. You will see PCMH concepts woven into the blog as well.
The Who. This blog is a partnership between the Center for Health IT and Family Practice Management Journal. Both will be contributing posts and comments to the blog. We also intend to have guest bloggers from the broader health care industry and from family medicine specifically who are working toward optimal use of health IT in their work and practice. Please let us know if you would like to tell your story by sending me an e-mail at email@example.com.
I look forward to our dialogue as we journey together to keep family medicine on the cutting edge of quality, safety, and efficiency through the meaningful use of health IT.
Steven E. Waldren, MD, MS
Director, Center for Health IT
American Academy of Family Physicians