Clinicians who want to access “meaningful use” incentive moneys (called by CMS the “EHR Incentive Program”) will need to register with CMS. Registration begins on Monday, January 3, 2011, and is open-ended. A clinician does not need to have a Certified EHR (or all the component Modules needed to cover all the criteria) in place at the time of registration – the technology only needs to be in place and used continuously for 90 days some time before the end of 2011 in order to access full payments for 2011.
Registration is fairly straightforward, and is accessed through the same portal that clinicians used to obtain an NPI (national provider identifier) number, as well as to enroll in Medicare in the first place – the Provider Enrollment, Chain and Ownership System (PECOS). When signing up, the clinician may well already have already created an enrollment in PECOS. If uncertain, the clinician can verify enrollment status; otherwise an enrollment can be obtained via the Internet directly.
Registration for the EHR Incentive Program is different, depending on whether access is desired through Medicare or through Medicaid. For Medicare, since that is administered federally, the registration is via the PECOS system, as described above. Enrolled clinicians who have satisfied all the Meaningful Use Criteria by the end of 2011 are eligible to receive 75% of their Medicare allowable charges, up to a ceiling of $44,000 cumulatively (paid out yearly, with the 2011 maximum being $18,000). In other words, a clinician needs to have billed Medicare $25,000 in 2011 (over the whole year) in order to be eligible for the maximum.
For Medicaid, things are different. In order to qualify for Incentive Payments via this route, a clinician needs 30% of the practice to be Medicaid (or 20% for pediatricians). Medicaid incentive payments pay a little more, with a ceiling of $63,750 cumulatively. Being administered by each state, Medicaid enrollment varies according to the state. Some states (Alaska, Iowa, Kentucky, Louisiana, Oklahoma, Michigan, Mississippi, North Carolina, South Carolina, Tennessee and Texas) will begin enrollment on January 3, 2011, just like Medicare. Other states (California, Missouri, North Dakota) will open their registration process in February. Other states will “likely” launch their Medicaid EHR Incentive Programs during the spring and summer of 2011.
The enrollment process is used to verify the identity of each participating clinician. It will the through this portal that Attestation for Meaningful Use will be submitted in 2011. Completion of each Meaningful Use criteria – for ambulatory practitioners, there are 15 “core” and 5-of-10 “menu” items which must be attested – must be done by the end of 2011 to receive payments. Some of the criteria have exclusions, and may be attested using a zero denominator if appropriate – for example a clinical discipline that does not write prescriptions may have zero as a denominator for the e-prescribing criterion.
As builders of Certified EHR technology, Practice Fusion is committed to building and providing all of the elements needed to demonstrate Meaningful Use – and do so free of charge to our clinician users. Our intent is to create “meaningful use tools” within our web-based EHR product that will easily display at-a-glance how the clinician is doing with respect to each of the needed criteria. We will make announcements as we build these elements and include them in our product.
Robert Rowley, MD
Chief Medical Officer
Practice Fusion EMR
