| EHR
Incentive Program Establishes Eligibility And Payment Calculations
CMS partnered with the Office of National
Coordinator
for Health Information Technology (ONC) to establish the electronic
health record (EHR) incentive program, defining "meaningful use" of
HIT, eligible participants and payment calculations.
Another product of the American Recovery and
Reinvestment Act of 2009, the EHR incentive program will provide
payments over a six-year period specific to Medicare and Medicaid. If
EHR has not been adopted, nor meaningful use achieved, all providers
will be subjected to lower payment updates for services after 2015.
"The Medicare EHR incentive program will provide
incentive payments to eligible professionals (EPs), eligible hospitals
and critical access hospitals (CAHs) that are meaningful users of
certified EHRs. The Medicaid EHR incentive program will provide
incentive payments to EPs and hospitals for efforts to adopt, implement
or upgrade certified EHR technology or for meaningful use in the first
year and for up to another five years," CMS said.
CMS proposed to implement the definition of
‘meaningful use’ through three stages. The first
stage
designates the "criteria for meaningful use to focus on electronically
capturing health information in a coded format, using that information
to track key clinical conditions, communicating that information for
care coordination purposes and initiating the reporting of clinical
quality measures and public health information."
The first stage will begin in 2011; CMS proposed
25
measures for EPs and 23 for eligible hospitals. For the complete list,
visit: http://edocket.access.gpo.gov/2010/pdf/E9-31216.pdf.
EPs must select which program to receive payments
under,
while hospitals can collect from both Medicare and Medicaid’s
incentive program. EPs and hospitals under the Medicaid program must
select which state to receive their payment from.
Medicare Incentive Program
To be an EP under the Medicare program, the
participant
must be: a doctor of medicine or osteopathy, a doctor of dental surgery
or dental medicine, a doctor of podiatric medicine, a doctor of
optometry or a chiropractor who is legally authorized to practice under
state law.
A qualifying EP can receive up to $44,000;
receiving
payments beginning in 2011. For the first year enrolled in the program,
an EP can receive $18,000 (in 2011 or 2012), for the following years
incentive payments will be $15,000, $12,000, $8,000, $4,000 and $2,000.
(See Table 1).
|
Calendar Year
|
Table1: First CY in which the EP
Receives an Incentive Payment
|
2015 and subsequent
years
|
|
2011
|
2012
|
2013
|
2014
|
|
2011
|
$18,000
|
|
|
|
|
|
2012
|
$12,000
|
$18,000
|
|
|
|
|
2013
|
$8,000
|
$12,000
|
$15,000
|
|
|
|
2014
|
$4,000
|
$8,000
|
$12,000
|
$12,000
|
|
|
2015
|
$2,000
|
$4,000
|
$8,000
|
$8,000
|
$0
|
|
2016
|
|
$2,000
|
$4,000
|
$4,000
|
$0
|
|
Total
|
$44,000
|
$44,000
|
$39,000
|
$24,000
|
$0
|
Source: Centers for Medicare and Medicaid
Services.
CMS proposes the first year an EP applies and
receives
the incentive payment that the EHR reporting period will last a
continuous 90-day period within that year. For every year after the
first payment year the reporting period will be the entire year.
Other key points to a Medicare EP are:
- A qualifying EP will receive an incentive
payment
equal to 75 percent of Medicare allowable charges for covered
professional services furnished by the EP in a payment year, subject to
maximum payments.
- An EP who predominantly furnishes services in a
geographic Health Professional Shortage Area is eligible for a 10
percent increase in the maximum incentive payment amount raising the
total incentive payments that such an EP can receive to $48,400.
- After the initial designation, EPs will be
allowed to
change their program from the Medicare to the Medicaid EHR incentive
program once during the payment years 2010-2014.
- Payments under Medicare will be disbursed
through
Medicare Administrative Contractors (MACs) or carriers to the Tax
Identification Number provided by the qualifying EP.
- Hospital-based EPs who furnish substantially
(90
percent) all their services in a ‘hospital setting’
are not
eligible for payments.
An eligible hospital for Medicare incentive
payments is
a ‘subsection (d) hospital’ paid under the hospital
inpatient prospective system located within the 50 states or the
District of Columbia.
The incentive payment is based on:
- an initial amount which is the sum of a $2
million
base amount and the product of a per discharge amount and the number of
discharges;
- the Medicare share which is the proportion of
Medicare fee-for-service and managed care inpatient bed-days to the
product of total inpatient days and by the hospital’s total
charges that are not attributed to charity care; and
- a transition factor which phases down the
incentive payments over the four-year period.
The transition factor follows the same model as
the EP
payment does; 1.00 will be used for 2011, decreasing by a quarter
increment each year. (See Table 2).
|
Fiscal Year
|
Table 2: Fiscal Year that Eligible
Hospital First Receives the Incentive Payment
|
|
2011
|
2012
|
2013
|
2014
|
2015
|
|
2011
|
1.00
|
|
|
|
|
|
2012
|
0.75
|
1.00
|
|
|
|
|
2013
|
0.50
|
0.75
|
1.00
|
|
|
|
2014
|
0.25
|
0.50
|
0.75
|
0.75
|
|
|
2015
|
|
0.25
|
0.50
|
0.50
|
0.50
|
|
2016
|
|
|
.025
|
0.25
|
0.25
|
Source: Centers for Medicare and Medicaid
Services.
"Incentive payments will be made to qualifying
Medicare
Advantage (MA) organizations for the adoption and meaningful use of EHR
technology by their affiliated eligible hospitals ... an MA-affiliated
hospital is an eligible hospital that is under common corporate
governance with the MA organization and serves individuals enrolled by
the MA plan," said CMS.
CAHs are held to the same eligibility requirements
as
other hospitals. However their payment calculation is different: "a
qualifying CAH will receive an incentive payment amount equal to the
product of its reasonable costs incurred for the purchase of certified
EHR technology and its Medicare share percentage. The Medicare share
percentage equals lesser of (1) 100 percent or (2) the sum of the
Medicare share fraction for the CAH percentage points," said CMS.
Medicaid Incentive Program
"The Recovery Act amended the Medicaid statue to
provide
100 percent Federal Financial Participation (FFP) for state
expenditures for provider incentive payments to encourage Medicaid
healthcare providers to adopt, implement and operate certified EHR
technology. It also established a 90 percent FFP match for state
expenses for administration of the incentive payments and for promoting
EHR adoption," said CMS.
Providers in their first year under the Medicaid
incentive program can qualify for payment "by demonstrating any of the
following: that they have adopted (that is, acquired and installed),
implemented (that is, trained staff, deployed tools, exchanged data) or
upgraded (that is, expanded functionality or interoperability) a
certified EHR," said CMS.
An EP under the Medicaid program are: physicians,
dentists, nurse practitioners, certified nurse midwives and physician
assistants practicing predominantly in a federally qualified health
center or rural health clinic.
EPs can receive up to $63,750 over the six-year
period; pediatricians with Medicaid patient volumes between 20-29
percent.
EPs must annually meet patient volumes thresholds,
measured by a ratio where the numerator is the total number of Medicaid
patient encounters over any representative continuous 90-day period in
the most recent calendar year and the denominator is all patient
encounters over that same 90-day period. For all EPs except
pediatricians, the patient volume threshold is 30 percent; for
pediatricians it’s 20 percent.
EPs can not be hospital-based; the same
stipulation as under the Medicare program.
Eligible hospitals are acute care and
children’s
hospitals. An acute care hospital is a primary health facility where
the average length of patient stay is 25 days or fewer; they must also
meet a patient volume threshold of 10 percent being Medicaid patients.
Also hospitals with a CMS Certification Number with the last four
digits between 0001-0879 are eligible, including short term general
hospitals and the 11 cancer hospitals in the U.S.
CMS defines a children’s hospital as a
separately
certified children’s hospital, either freestanding or
hospital-within-hospital, that has a certification number with the last
four digits in the series 3300-3399 and predominantly treats
individuals under 21-years-old.
Calculation for hospital payment is the overall
EHR amount times the Medicaid share.
Address: Centers for Medicare and Medicaid
Services, 7500 Security Blvd., Baltimore, MD 21244; (877) 267-2323, www.cms.gov.
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