Medicare: Registration for individual providers is currently open through the CMS EHR Incentive Program website, however providers registering for the Medicare program now are not eligible to receive reimbursements but are able to prevent further penalty payment adjustments by registering and attesting to Meaningful Use. Providers do not need to be currently using a certified EMR in order to register. Registration can occur now and providers may go back at a later date to edit their registration to include their Certified EMR code, however successful attestation does require the use of a certified EMR.
What to plan for: If you haven’t yet implemented an EMR or are looking to replace your current software, start on you 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 vendors may have a backlog for implementation and its sometimes challenging to coordinate provider schedules to complete training.
Implementation timing and Medicare CMS EHR incentives: Providers who did not register for and attest to Meaningful Use in 2014 or earlier are no longer eligible to receive incentive payments, but may still wish to register for and attest to Meaningful Use to avoid penalty adjustments on Medicare payments. Providers who did not successfully attest to Meaningful Use in 2013 began to receive a payment adjustment of 1% in 2014, providers who did not successfully attest to Meaningful Use in 2014 are experiencing payment adjustments of 2% in 2015, and providers who do not successfully attest to Meaningful Use in 2015 can expect payment adjustments of 3% in 2016. 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.
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 is 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.
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 avoid penalty adjustments. 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 latest 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 for them, 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 year of participation, attestation can occur when a provider has completed 90 consecutive days of successful meaningful use within the single calendar year. 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. In the second payment year, the provider will need to prove meaningful use of the EMR for 90 consecutive days. In the third and following payment years, the provider will need to attest to 365 consecutive days of EMR meaningful use.
Medicare: Providers who have not registered for and began attesting to Meaningful Use prior to 2014 are not eligible for incentive payments, but may still wish to participate in the Meaningful Use program to avoid penalty adjustments to Medicare payments. For providers who registered and began successfully attesting to Meaningful Use in 2014 or earlier, incentive payments 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 EP meets the threshold in allowed charges for the payment year.
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.