Who Qualifies for the Incentive?

Eligible Professionals (EPs) under the incentive program are limited to physicians as defined by the Social Security Act. Those physicians are:

• A doctor of medicine or osteopathy
• A doctor of surgery or of dental medicine
• A doctor of podiatric medicine
• A doctor of optometry
• A chiropractor

Medicare

To receive Medicare incentive payments, EPs must:

• Not be hospital based
• Demonstrate meaningful use of a certified EHR (see further discussion below)

Medicaid

The Medicaid incentive payments expands the definition of EPs to include:

• Certified nurse mid-wife
• Nurse practitioner
• Physician assistant (under certain circumstances)

To receive Medicaid incentive payments, EPs must:

• Not be hospital based
• Demonstrate meaningful use of a certified EHR (see further discussion below)
• Treat a patient population, of which at least 30% receive medical assistance (or 20% if the physician is a pediatrician

Medicare

To qualify for the maximum bonus, providers must be able to demonstrate meaningful use of a certified system by 2012. Maximum bonus totals are shown in the graph below. To determine what a provider would receive, the following needs to be considered. The incentive payment is equal to 75% of Medicare allowable charges for covered services furnished by the provider in a year. Therefore, a physician wanting to receive the full first year payment of $18,000 would need to submit allowable charges to Medicare of at least $24,000. If a provider submits $18,000 for allowable charges, then their payment would be $13,500.

Medicare Incentive Schedule

* For the first year for which an EP applies for and receives an incentive payment, the EHR Reporting Period is 90 days for any continuous period beginning and ending within the year. For every year after the first payment year, the EHR reporting period is the entire year.

The Incentive Schedule also allows for an additional reimbursement of 10% for physicians providing services in areas designated by the Secretary of HHS as a "health professional shortage area."

If Medicare providers choose not to implement an EHR system, the amount received under the Medicare Fee Schedule will be reduced in the following manner:

• 1.0% for 2015; 2% for 2016; and 3% for 2017 and each subsequent year.
• For 2018, and each subsequent year, that less than 75% of EPs are meaningful users, the applicable fee schedule amount is further adjusted downward by one percentage point each year, down to a maximum of 5%.

Medicaid

Although providers can also receive incentives under the Medicaid program, it’s important to note that benefits can only be received from either the Medicare or the Medicaid program. Providers will not incur penalties for non-participation in the Medicaid program.

In order to qualify for the Medicaid program, doctors must have a patient volume at least 30 percent attributable to Medicaid patients or, if they practice predominantly in a federally qualified health center or rural health clinic, they have patient volume at least 30 percent attributable to Medicaid patients and other needy individuals as defined by Medicaid rules. In addition, providers are eligible if they have a minimum 20% Medicaid patient volume AND are pediatricians. (CHIP patients do not count towards Medicaid patient volume criteria).

http://www.cms.gov/EHRIncentivePrograms/15_Eligibility.asp

Medicaid Incentive Schedule

http://www.cms.gov/MLNProducts/downloads/EHRIP_Eligible_Professionals_Tip_Sheet.pdf

What is the Timeline for both Incentive Programs?

http://www.cms.gov/EHRIncentivePrograms/Downloads/EHRIncentProgtimeline508.pdf

Reporting Period

The reporting period for the EHR Incentive program using a certified EHR is any continuous 90-day period during the first payment year. Please note that although the measure specifications assume a full calendar year you should only calculate the denominator and numerator from the first day of the 90 day reporting period to the last day of the 90 day reporting period.

http://www.cms.gov/QualityMeasures/

First year of demonstration: Any continuous 90-day period within the payment year Sample dates

• January 1, 2011 to April 1, 2011
• March 13, 2011 to June 11, 2011
• September 10, 2001 to December 9, 2011

Unallowable: November 1, 2011 to January 31, 2012 because it crosses into the next year

Meaningful Use

Specifics of Stage 1 Meaningful Use (2011 and 2012)


Meaningful use includes both a core set and a menu set of objectives that are specific for eligible professionals and hospitals. For Eligible Professionals, there are a total of 25 meaningful use objectives. 20 of the objectives must be completed to qualify for an incentive payment. 15 are core objectives that are required, and the remaining 5 objectives may be chosen from the list of 10 menu set objectives.

The definition of meaningful use includes reporting of clinical quality measures.

To realize improved health care quality, efficiency and patient safety, the criteria for meaningful use will be staged in three steps over the course of the next five years. Stage 1 sets the baseline for electronic data capture and information sharing. Stage 2 (est. 2013) and Stage 3 (est. 2015) will continue to expand on this baseline and be developed through future rule making.

http://www.cms.gov/EHRIncentivePrograms/

How will providers demonstrate Meaningful Use?

For 2011, CMS will accept provider attestations for demonstration of all the meaningful use measures, including clinical quality measures. Starting in 2012, CMS will continue attestation for most of the meaningful use objectives but plans to initiate the electronic submission of the clinical quality measures. States will also support attestation initially and then subsequent electronic submission of clinical quality measures for Medicaid providers’ demonstration of meaningful use.

How and when will incentive payments be made?

CMS expects to initiate Medicare incentive payments nine months after the publication of the final rule. For Medicaid, States are determining their own deadlines for launching their Medicaid EHR Incentive programs but are required to make timely payments, per the CMS final rule. CMS expects that the majority of States will have launched their programs by the summer of 2011.