Attestation is the part of the process to secure CMS EHR Incentive Program reimbursements that requires providers to prove (attest to) that they are meaningfully using a certified EMR. Both the CMS Medicare and Medicaid programs will require attestation through the CMS website and the state Medicaid program for which the provider registered may have additional requirements. Attestation will likely be a combination of the provider self proclamation and reporting from the EMR to prove the consistent meaningful use to achieve the core and menu set meaningful use requirements. Attestation will occur through the CMS EHR Incentive Program website.
Each program may vary in attestation requirements; essentially, how the provider proves meaningful use of a certified EMR. Providers should do their due diligence to know what will be required so that they are prepared to attest as soon as possible after 90 days of consecutive meaningful use in the first year in which the provider is interested in securing reimbursement. The attestation phase of the CMS EHR Incentive Program is also completed through the CMS website, although each state Medicaid organization may require submission of additional information to them directly. Providers should verify this with their state Medicaid organization.
Yes. For the first Medicare payment year and the second Medicaid payment year, in order to secure payment in a given calendar year, EPs would need to complete their 90 days of consecutive meaningful use of a certified EMR in the same year in which the first payment is desired. EPs may not overlap calendar years to secure the payment.
Yes. Different EPs may start their programs at different times during the year, or even in different years.
Incentive payments for the Medicare EHR Incentive Program will be made approximately four to eight weeks after an EP successfully attests to demonstrated meaningful use of certified EHR technology. However, EPs will not receive incentive payments within that time frame if they have not yet met the threshold for allowed charges for covered professional services furnished by the EP during the year.
The Medicare EHR incentive payments to EPs are based on 75 percent of the estimated allowed charges for covered professional services furnished by the EP during the entire payment year. Therefore, to receive the maximum incentive payment of $18,000 for the first year of participation in 2011 or 2012, the EP must accumulate $24,000 in allowed charges. If the EP has not met the $24,000 threshold at the time of attestation, CMS will hold the incentive payment until the EP meets the threshold in order to maximize the amount of the EHR incentive payment the EP receives. As an example, if an EP has not met the $24,000 threshold by the end of calendar year, CMS expects to issue an incentive payment for the EP in March of the following year (allowing 60 days after the prior year's end for all pending claims to be processed).
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