EMR Incentive Center
FAQs Program Timing
- What to plan for: Start on your EMR vendor selection sooner rather than later. Take the time to complete a workflow analysis and interview your staff to understand what you need from an EMR. Then conduct your due diligence as you compare multiple vendors in an apples-to-apples comparison. Once you have selected and purchased your EMR, keep in mind that many organizations will need to purchase and install upgraded hardware to meet vendor performance requirements for current EMR and/or PM software. Then coordinate with your vendor to determine a mutual training schedule; not always an easy feat considering many vendors have a backlog for implementation and its often challenging to coordinate provider schedules to complete training.
- Implementation timing and Medicare CMS EHR incentives: CMS EHR incentives are designed to reimburse providers the maximum amount if starting the program in 2011 or 2012. In order to secure the first year of incentive payment in 2012, providers need to start the 90 days of consecutive meaningful use no later than October 1, 2012. ***Providers should keep in mind that the first year of 90 days consecutive meaningful use MUST be completed in a single year. There is no overlapping of the years. For example, a provider will not be considered as having achieved meaningful use if 30 days of it was completed in December 2011, with the remaining 60 days spilling over in 2012. The provider would need to wait until January 1, 2012 to complete the entire 90 days of consecutive meaningful use, essentially starting 2012 as the first payment year.
- Implementation timing and Medicaid CMS EHR incentives: The Medicaid program is dependent on two things. First, whether or not the state is participating in an incentive program and when registration will be available. Second, when Adoption/Implementation/Upgrade (A/I/U) to certified EMR software occurred. As long as the state Medicaid organization has opened registration for its incentive program and the provider can prove A/I/U, attestation can occur to secure payment for the first payment year. But, keep in mind, the second payment year will require 90 days of consecutive meaningful use. Providers may consider waiting until 2012 to attest to A/I/U as their first payment year. This will allow a bit of time to ensure MU training and ensure provider adoption to complete required MU in 2013.
Achieving Meaningful Use
- Medicare: Providers must complete their 90 days of consecutive meaningful use according to Medicare requirements for the first year in which a provider desires to be paid. Subsequent years will require 365 days of meaningful use according to the current requirements for each future payment year. Providers that already have EMR software will need to ensure they get upgraded to the ONC-ATCB certified version and get trained up on how to meaningfully use the EMR before attempting to complete meaningful use. New EMR users will probably need some extra time, as not only will meaningful use be a new concept, but the EMR electronic workflow will be new as well. Set realistic target dates for upgrade, training and monitoring to ensure adoption of meaningful use functionality.
- Medicaid: Providers must prove A/I/U during the first year in which payment is desired. In payment year 2, providers will need to achieve 90 consecutive days of meaningful use as defined by the individual state Medicaid organization.
- Medicare: For the first payment year, attestation can occur when a provider has completed 90 consecutive days of successful meaningful use within the single calendar year in which the first year of payment is desired. Providers should also consider whether or not they have achieved the required Medicare Part B billing in order to be eligible for the maximum amount. Visit the CMS EHR Incentive Program Attestation webpage for information on how to attest.
- Medicaid: For the first payment year, attestation can occur when the provider has compiled the A/I/U documentation and/or data required by the individual Medicaid organization.
- Medicare: Incentive payments for the Medicare EHR Incentive Program will be made approximately four to eight weeks after an eligible professional meets the program requirements and successfully attests they have demonstrated meaningful use of certified EHR technology. Payments will be held for eligible professionals until the eligible professional meets the $24,000 threshold in allowed charges for the payment year. Meaning that if a provider attest to 90 days of MU in April 2012 but does not yet meet the $24,000 in Medicare Part B charges, payment will be held until the provider does. Payments will be held until the EP meets the $24,000 threshold in allowed charges for calendar year 2011 in order to maximize the amount of the EHR incentive payment they receive. If the EP has not met the $24,000 threshold in allowed charges by the end of calendar year 2011, CMS expects to issue an incentive payment for the EP in March 2012 (allowing 60 days after the end of the 2011 calendar year for all pending claims to be processed).
- Medicaid: Medicaid incentives are paid by the states. States are required to issue incentive payments within 45 days of providers successfully attesting to having Adopted, Implemented or Upgraded to certified EHR technology during their first year of participation in the Medicaid EHR Incentive Program. Launch date for the Medicaid EHR Incentive Program varies by state, so the earliest date attestation can begin also varies by state.
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