Electronic Health Record (EHR) Incentive Program

Penalties Begin 2013 for Non-Participation

Electronic Health Record (EHR) Incentive Program
Penalties Begin 2013 for Non-Participation

EHR Incentive Program Basics
List of Certified EHRs
Regional Extension Centers
Important Dates
CMS EHR Incentive Page
EHR Incentive Program Listserv
Frequently Asked Questions

What is an EHR?
Sometimes people use the terms "Electronic Medical Record" or "EMR" when talking about Electronic Health Record (EHR) technology. Very often an Electronic Medical Record or EMR is just another way to describe an Electronic Health Record or EHR, and both providers and vendors sometimes use the terms interchangeably. For the purposes of the Medicare and Medicaid Incentive Programs*, eligible professionals, eligible hospitals, and critical access hospitals (CAHs) must use ¬certified EHR technology.

What is certified EHR technology?
Certified technology simply means an electronic health record has met certain criteria. Standards, implementation specifications, and certification criteria for EHR technology have been adopted by the Secretary of the Department of Health and Human Services.

Who certifies EHRs?
EHR technology must be tested and certified by an Office of the National Coordinator (ONC) Authorized Testing and Certification Body (ATCB) in order for a provider to qualify for EHR incentive payments.

List of Certified EHRs

Why do the EHRs need to be certified?
Certified EHRs give assurance to purchasers and other users that an EHR system or module offers the necessary technological capability, functionality, and security to help them meet the meaningful use criteria. Certification also helps providers and patients be confident that the electronic health IT products and systems they use are secure, can maintain data confidentially, and can work with other systems to share information. For more information about which EHR systems and modules are certified for the Medicare and Medicaid EHR* Incentive Programs, please visit http://healthit.hhs.gov/.

REMEMBER: You do not need to have your certified EHR technology in place to register for the EHR incentive programs!However, you must adopt, implement, upgrade, or successfully demonstrate meaningful use of certified EHR technology under the Medicaid EHR* Incentive Program and successfully demonstrate meaningful use of certified EHR technology under the Medicare EHR Incentive Program before you can receive an EHR incentive payment (see below for definitions of adopted, implemented and upgraded based on CMS’ website).

What does “meaningful use” mean?
The American Recovery and Reinvestment Act of 2009 specifies three main components of Meaningful Use:

  1. The use of a certified EHR in a meaningful manner, such as e-prescribing.
  2. The use of certified EHR technology for electronic exchange of health information to improve quality of health care.
  3. The use of certified EHR technology to submit clinical quality and other measures.

Simply put, "meaningful use" means providers need to show they're using certified EHR technology in ways that can be measured significantly in quality and in quantity.

How is meaningful use met?

To qualify for incentive payments, meaningful use requirements must be met in the following ways:

  • Medicare EHR Incentive Program—Eligible professionals, eligible hospitals, and critical access hospitals (CAHs) must successfully demonstrate meaningful use of certified electronic health record technology every year they participate in the program.
  • Medicaid EHR* Incentive Program: Eligible professionals and eligible hospitals may qualify for incentive payments if they adopt, implement, upgrade or demonstrate meaningful use in their first year of participation. They must successfully demonstrate meaningful use for subsequent participation years.
  • Adopted: Acquired and installed certified EHR technology. (For example, can show evidence of installation).
  • Implemented: Began using certified EHR technology. (For example, provide staff training or data entry of patient demographic information into EHR).
  • Upgraded: Expanded existing technology to meet certification requirements. (For example, upgrade to certified EHR technology or add new functionality to meet the definition of certified EHR technology).

Why should I participate in the EHR program?Eligible providers, who meet the meaningful use requirements with a certified EHR, may qualify to receive up to $44,000 in the Medicare EHR incentive program or $63,750 in the Medicaid EHR*incentive program.

What are the consequences for non-participation in an EHR incentive program?
For 2015 and later, Medicare eligible professionals who do not successfully demonstrate meaningful use will have a payment adjustment to their Medicare reimbursement. The payment reduction starts at 1% and increases each year that a Medicare eligible professional does not demonstrate meaningful use, to a maximum of 5%.

Medicaid eligible professionals who also treat Medicare patients will have a payment adjustment to Medicare reimbursements starting in 2015 if they do not successfully demonstrate meaningful use.

Who are considered EPs (eligible professionals)?
Eligible providers for the Medicare EHR incentive program are doctors of medicine, osteopathy, dental surgery, dental medicine, podiatry, optometry, and chiropractors.

Eligible providers for the Medicaid EHR* incentive program are Physicians (primarily doctors of medicine and doctors of osteopathy), Nurse practitioners, certified nurse-midwifes, Dentists, physician assistant who furnishes services in a Federally Qualified Health Center or Rural Health Clinic that is led by a physician assistant.

CMS Eligibility

Is there a specific criterion that must be met for a Medicare or Medicaid EP (eligible provider)?
To qualify for an incentive payment under the Medicaid EHR* Incentive Program, an eligible professional must meet one of the following criteria:

  • Have a minimum 30% Medicaid patient volume*
  • Have a minimum 20% Medicaid patient volume, and is a pediatrician*
  • Practice predominantly in a Federally Qualified Health Center or Rural Health Center and have a minimum 30% patient volume attributable to needy individuals
  • Children's Health Insurance Program (CHIP) patients do not count toward the Medicaid patient volume criteria.

There are no minimum requirements on Medicare patient volumes.

Hospital-based eligible professionals are not eligible for incentive payments for either Medicare or Medicaid EHR* Incentive programs. An eligible professional is considered hospital-based if 90% or more of his or her services are performed in a hospital inpatient (Place of Service code 21) or emergency room (Place of Service code 23) setting.

What is the first step to participate in an EHR incentive program for EPs?
All eligible providers must have an NPI number and be registered in PECOS (Provider Enrollment Chain and Ownership System).

Is registration required to participate in an EHR Incentive Program? Registration is required to participate in an EHR Incentive Program. Registration requires:

  • National Provider Identifier (NPI).
  • National Plan and Provider Enumeration System (NPPES) User ID and Password.
  • Payee Tax Identification Number (if you are reassigning your benefits).
  • Payee National Provider Identifier (NPI)(if you are reassigning your benefits).

Register for an EHR incentive program

UPDATE regarding third-party registration:
In April 2011, CMS implemented functionality that allows an EP to designate a third party to register and attest on his or her behalf. To do so, users working on behalf of an EP must have an Identity and Access Management System (I&A) web user account (User ID/Password), and be associated to the EP's NPI. If you are working on behalf of an EP(s), and do not have an I&A web user account, please visit I&A Security Check to create one. States will not necessarily offer the same functionality for attestation in the Medicaid EHR Incentive Program. Check with your State to see what functionality will be offered.

Please be aware that eligible professionals currently are not permitted to allow a practice manager or any other person to register in their place. Sharing your National Plan and Provider Enumeration System (NPPES) user ID and password with third parties can place your information at risk. Until CMS implements new functionality in May 2011, each EP should register himself or herself separately for the Medicare and Medicaid EHR* Incentive Programs.

Is participation allowed for both Medicare and Medicaid EHR* Incentive Programs?
Eligible professionals that are eligible for both the Medicare and Medicaid EHR* Incentive Programs must choose which incentive program they wish to participate in when they register. Most eligible professionals will maximize their incentive payments by participating in the Medicaid EHR* Incentive Program.

Can participants switch between Medicare EHR and Medicaid EHR* Incentive Programs during the year?
Before 2015, an eligible professional may switch programs only once after the first incentive payment is initiated.

Important Dates to Remember

  • October 1, 2010 – Reporting year begins for eligible hospitals and CAHs.
  • January 1, 2011 – Reporting year begins for eligible professionals.
  • January 3, 2011 – Registration for the Medicare EHR Incentive Program begins.
  • January3, 2011 – For Medicaid providers, states may launch their programs if they so choose.
  • April 2011 – Attestation for the Medicare EHR Incentive Program begins.
  • May 2011 – EHR Incentive Payments expected to begin.
  • July 3, 2011 – Last day for eligible hospitals to begin their 90-day reporting period to demonstrate meaningful use for the Medicare EHR Incentive Program.
  • September 30, 2011 - Last day of the federal fiscal year. Reporting year ends for eligible hospitals and CAHs.
  • October 1, 2011 – Last day for eligible professionals to begin their 90-day reporting period for calendar year 2011 for the Medicare EHR Incentive Program.
  • November 30, 2011 – Last day for eligible hospitals and critical access hospitals to register and attest to receive an Incentive Payment for Federal fiscal year (FY) 2011.
  • December 31, 2011 – Reporting year ends for eligible professionals.
  • February 29, 2012 – Last day for eligible professionals to register and attest to receive an Incentive Payment for calendar year (CY) 2011.

*Not all states have opened the Medicaid EHR incentive program. Please check here to see if and when your state is scheduled to begin participation.

Still confused on EHR Incentive Programs?

An electronic health record must be able to submit clinical quality and other measures, must have the capability to exchange health information to improve quality care and have a “meaningful use”. “Meaningful use” must be demonstrated through a certified EHR. The benefits of “meaningful use” are financial incentives, reduction in errors, availability of records and data, reminders and alerts to patients and staff, clinical decision support, e-prescribing and refill automations. CMS developed a MLN product that provides a brief overview of the program and may answer questions relating to participation in other CMS incentive programs, payments and adjustments, timeframes, etc. CMS’ timeline on the incentive programs can be found there and a flow chart of eligibility can be found here. There are tools to assist providers with registration for EHR incentive programs. CMS created a video with step-by-step instructions on registering. Information regarding the Medicaid EHR incentive plan can be found on the Medicaid State Information website.

EHR Fast Facts

  • Two EHR programs
  • Medicare
  • Medicaid
  • Doctors of osteopathic, medicine, dental surgery, dental medicine, podiatric, optometry, and chiropractors are eligible to participate in Medicare
  • Physicians, NPs (nurse practitioners), certified nurse-midwives, dentists, PAs (physician assistants) working in FQHCs (Federally qualified health center)or RHCs (Rural health clinic) may participate in Medicaid
  • EP (eligible participants) can not be hospital based in either program
  • EPs may participate in either the Medicare or Medicaid program
  • EPs must have an NPI (national provider identifier)
  • EPs must be registered in PECOS (Provider Enrollment Chain and Ownership System)
  • EPs must also register on EHR incentive website
  • EHR must be certified through an ONC technology authorized testing and certified body
  • Either Medicare or Medicaid EHR incentive program may be reported with PQRS
  • Medicaid EHR incentive program can be reported with eRx-NOT with Medicare EHR incentive program
  • 3 stages of implementation
  • Stage 1 (2011 and 2012) sets the baseline for electronic data capture and information sharing.
  • EPs must attest to demonstrating meaningful use for 90 days during 1st year and subsequent year
  • EPs must report on 20 of 25 objectives
  • EPs must report on at least 10 measures from January 1, 2011 through June 30, 2011
  • Stage 2 (expected to be implemented in 2013)
  • Stage 3 (expected to be implemented in 2015) will continue to expand on this baseline and be developed through future rule making.

New Toolkit Helps Medical Practices Examine the Impact of Health IT on Workflow

A new toolkit funded by AHRQ and prepared by the University of Wisconsin-Madison’s Center for Quality and Productivity Improvement (CQPI) will assist small and medium sized practices in workflow analysis and redesign before, during, and after health IT implementation. The toolkit, Workflow Assessment for Health IT, includes tools to analyze workflow, examples of workflow analysis and redesign, and others’ experiences with health IT and workflow. For more information and a copy of the toolkit go to http://healthit.ahrq.gov/workflow

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