EHR Incentive Programs for Physicians –- Act Now!

By Nancy O’Connor

Did you know incentive payments are available to certain health care professionals that adopt certified Electronic Health Record (EHR) technology and show they’ve used it to help improve quality, safety, and effectiveness of care?

Starting this year, Medicare and Medicaid will provide significant EHR incentive payments to health care professionals. Physicians and other health care providers that sign up for the Medicare EHR Incentive Program in 2011 or 2012 can receive up to $44,000 per provider over the life of the program.  So an office with three doctors could receive up to $132,000. The payments could be even higher under Medicaid EHR Incentive Program.

The Medicare and Medicaid Electronic Health Records Incentive Programs were established by the Health Information Technology for Economic and Clinical Health Act (HITECH), part of the American Recovery and Reinvestment Act of 2009.

Who is Eligible?

The Medicare and Medicaid EHR Incentive Programs have slightly different eligibility requirements.  Eligible professionals under the Medicare program may include:

• Doctor of medicine or osteopathy
• Doctor of dental surgery or dental medicine
• Doctor of podiatry
• Doctor of optometry
• Chiropractor

Eligible professionals under the Medicaid program may include:

• Physicians (primarily doctors of medicine and doctors of osteopathy)
• Nurse practitioner
• Certified nurse-midwife
• Dentist
• Physician assistant who furnishes services in a Federally Qualified Health Center that is led by a physician assistant or Rural Health Clinic that is so led.

In addition, eligible professionals who wish to participate in the Medicaid EHR Incentive Program have to meet certain volume thresholds:

• Have a minimum 30% Medicaid patient volume*
• Have a minimum 20% Medicaid patient volume, and is a pediatrician*
• Practice predominantly in a Federally Qualified Health Center or Rural Health Center and have a minimum 30% patient volume attributable to needy individuals

* Children’s Health Insurance Program (CHIP) patients do not count toward the Medicaid patient volume criteria.

If you are eligible for both the Medicare and Medicaid EHR Incentive Programs, you must choose which program to participate in when you register.  Before 2015, you may switch programs only once after the first incentive payment is initiated. Most eligible professionals will maximize their incentive payments by participating in the Medicaid EHR Incentive Program.

The Medicare and Medicaid EHR Incentive Programs are new and separate programs from other active CMS incentive programs, such as the Physicians Quality Reporting System (PQRS, formerly known as the Physician Quality Reporting Initiative or PQRI) and the Medicare Improvements for Patients and Providers Act (MIPPA) E-Prescribing Incentive Program.  A physician who chooses to participate in the Medicare EHR incentive program cannot receive incentive payments from the MIPAA E-prescribing incentive program for the same period.

What is Certified EHR Technology?

Both the Medicare and Medicaid EHR Incentive Programs require the use of certified EHR technology. Standards, implementation specifications, and certification criteria have been adopted by the Department of Health and Human Services. EHR technology must be tested and certified by an Office of the National Coordinator (ONC) Authorized Testing and Certification Body (ATCB) in order for a provider to qualify for EHR incentive payments; even if you are already using EHR technology, it must be tested and certified by an ONC-ATCB specifically for the Medicare and Medicaid EHR Incentive Programs.

EHR technologies that meet the certification requirements for the Medicare and Medicaid EHR Incentive Programs are listed on the ONC Web site at http://onc-chpl.force.com/ehrcert.  Keep in mind that you do not need to have your certified EHR technology in place in order to register for the EHR Incentive Programs! However, you must adopt, implement, upgrade, or successfully demonstrate meaningful use of certified EHR technology under the Medicaid EHR Incentive Program and successfully demonstrate meaningful use of certified EHR technology under the Medicare EHR Incentive Program before you can receive an EHR incentive payment.

Registration

Registration for the Medicare EHR Incentive Program is now open. The Medicaid EHR Incentive Program has opened in other states, but Pennsylvania has not yet implemented its program.

Registering for the EHR Incentive Programs only takes a few simple steps.

Before an eligible professional can register, you must be sure to have a national provider identifier (NPI) number, and, for the Medicare incentive program only, have an enrollment record in the Provider Enrollment, Chain and Ownership System (PECOS).  If you aren’t sure if you have a record in PECOS, you can check online at https://pecos.cms.hhs.gov/pecos/login.do or contact Highmark Medicare Services at 1-866-488-0549, option 1.

Once you are sure that you have an enrollment record in Medicare’s system, online registration is easy.  Be sure to have the following documents handy:

• National Provider Identifier (NPI).
• National Plan and Provider Enumeration System (NPPES) User ID and Password.
• Payee Tax Identification Number (if you are reassigning your benefits to a group).
• Payee National Provider Identifier (NPI) (if you are reassigning your benefits).

Please be aware that eligible professionals currently are not permitted to allow a practice manager or any other person to register in their place. Sharing your NPPES user ID and password can place your information at risk. However, beginning in May 2011, CMS plans to allow an eligible professional to designate a third party who can register and attest on behalf of an eligible professional. States may not necessarily offer the same functionality for the Medicaid EHR Incentive Program.

To start the online registration process, simply point your web browser to https://ehrincentives.cms.gov/hitech/login.action and select the link titled “Eligible Professionals”

Attestation:

In order to earn the incentive payments in 2011, you will be asked to attest through an online system that you have used certified EHR technology in a meaningful way. Attestation will begin in April, with initial incentive payments made in May.

Payment Adjustments:

If you do not sign up for either the Medicare or Medicaid EHR Incentive Programs, and therefore do not successfully demonstrate meaningful use of certified EHR technology, your Medicare physician fee schedule amount for covered professional services will be adjusted beginning in 2015. The payment adjustments will be as follows:

• 2015—99 percent of Medicare physician fee schedule covered amount
• 2016—98 percent of Medicare physician fee schedule covered amount
• 2017 and each subsequent year—97 percent of Medicare physician fee schedule covered amount. (In 2018 and subsequent years, the Secretary may adjust the physician fee schedule by a percentage lower than 97 percent in certain circumstances, but in no case will the applicable percent be less than 95 percent.)

The Recovery Act allows for case-by-case significant hardship exceptions, which, if applicable, could exempt certain eligible professionals from the payment adjustment. The exemption is subject to annual renewal, but in no case will it be given for more than five years.

This payment adjustment does not apply to the Medicaid EHR Incentive Program.

To learn more about the programs, visit the official EHR Incentive Programs Web site at www.cms.gov/EHRIncentivePrograms. The sooner you act, the more you can receive.

 

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Nancy O’Connor is Regional Administrator for Philadelphia, Centers for Medicare & Medicaid Services.