EHR Incentive Payment Schedule: When do I get my Meaningful Use money?

The EHR Incentive Program (“ Meaningful Use”) will pay Eligible Providers an incentive bonus for demonstrating “meaningful use of certified Electronic Health Record (EHR) technology,” beginning in 2011. But when and how will these payments take place?

The Centers for Medicare and Medicaid Services (CMS), which administers this program, has recently updated their Frequently Asked Questions (FAQ) about payment timing and methods.

The program has two different methods of deployment: through Medicare or through Medicaid. A clinician needs to Register in order to participate in the program, and must choose either Medicare or Medicaid. In order to participate in Medicaid, a practice needs to have at least 30% of its business be Medicaid (or 20% for pediatricians); Medicare has no such thresholds.

Just like the underlying programs, Medicare is administered federally, and Medicaid is administered by each state. Similarly, the EHR Incentive Program payments through Medicare will be handled at the federal level, and the payments for participating through Medicaid is administered by the states. The various states differ widely in terms of their timelines for allowing Registration in the first place, as well as when they are open for Attestation and payment.

The Medicare payment methodology has now been better clarified by CMS. The amount of payments is 75% of an Eligible Provider’s (EP) Medicare allowed charges, up to a ceiling of $18,000 in the first year of the program – that means that an EP needs to bill at least $24,000 (over the course of the calendar year) to Medicare in order to reach the maximum.

Once an EP has Registered, and has used a Certified EHR for 90 consecutive days during the year (and has met the Meaningful Use criteria for that 90-day period), then they can submit an Attestation. Medicare will pay approximately 4 to 8 weeks after successful Attestation, in a lump sum, separate from ordinary Medicare payments.

However, EPs will not receive incentive payments within that timeframe if they have not yet met the $24,000 threshold for maximal payments. Medicare will wail until cumulative billing has reached the $24,000 level (even if it is later than Attestation), and disburse incentive payments once the threshold is reached. If the threshold has not been reached by the end of the calendar year, Medicare will wait until March 1, 2012 for all the “tail” of bills to come in, and then will make a payment of 75% of what has been received by then for the 2011 calendar year.

Payments will be made via the same methods that Medicare has established with each EP for ordinary payments – either check, or direct electronic funds transfer into the clinician’s bank account (if that has been set up). Note, though, that the Fiscal Intermediaries (FIs) and Medicare Administration Contractors (MACs) that make the regular Medicare payments to clinicians will not be the ones to administer the EHR Incentive payments – CMS has contracted with a single Payment File Development Contractor to make these payments (see details here).