Medicare EHR Incentive Program

Eligible professionals include:

• Doctor of medicine or osteopathy
• Doctor of dental surgery or dental medicine
• Doctor of podiatry
• Doctor of optometry
• Chiropractor

Eligible Hospitals include:

• "Subsection (d) hospitals" in the 50 states or DC that are paid under the Inpatient Prospective Payment System (IPPS)
• Critical Access Hospitals (CAHs)
• Medicare Advantage (MA-Affiliated) Hospitals

For more information on eligibility and to use the Eligibility Wizard, visit the CMS website.

Regarding the measures within Meaningful Use and attestation, you must consider patients from all payers to be counted in both the numerator and denominator. Where your Medicare patient volume does matter is with the amount you will receive in incentives. Your incentive payment will be based on 75% of allowed charges (up to $24,000). To earn the maximum incentive payment you must accumulate $24,000 in Medicare charges.

There is a minimum number of patient volume for the Medicaid program, but not the Medicare program:

• Have a minimum 30% Medicaid patient volume
• Have a minimum 20% Medicaid patient volume, and is a pediatrician

1. Make sure you are eligible for the Medicare EHR Incentive Program.
2. Register for the EHR Incentive Program. Click here if you are ready to register.
   Note: CMS published its new policy permitting third parties to register and attest for the Medicare and Medicaid EHR incentive program on behalf of eligible professionals (EPs). CMS requires users registering or attesting on behalf of an EP to have an Identity and Access Management System (I&A) Web user account that must be associated with the EP's National Provider Identifier. Practice administrators that do not have an I&A Web user account can create one on the CMS Website. 3. Use certified EHR technology.
3. Use certified EHR technology.
4. Successfully demonstrate meaningful use for 90 consecutive days for your first year of participation (a full year in each subsequent year)
5. Attest that you have demonstrated meaningful use with certified EHR technology (see attestation information below).

The AAN has joined with American EHR Partners to provide members with guidance and resources to assist in purchasing and implementing electronic health records (EHRs) in their practices. This partnership will provide neurologists across the United States with free access to the necessary tools to identify, implement, and effectively use EHRs and other health care technologies.

This site offers free registration to neurologists to compare EHR systems and access educational material about implementing EHRs. Neurologists can also review the EHR system they are already using.

Visit the AmericanEHR website to learn more, including:

• Interactive tools to help you measure your practice's readiness to adopt an EHR system
• A directory of vendors and tools to compare and rate vendors and instantly obtain vendor information
• Educational resources to help better understand meaningful use and how to implement an EHR system
• Tools to review the EHR system you are currently using

Note: The AAN makes no endorsements of specific products surveyed by AmericanEHR Partners, which is managed by Cientis Technologies and the American College of Physicians. Other partners in the system include the American College of Rheumatology, American Psychiatric Association, American Academy of Physician Assistants, Society of General Internal Medicine, and the Infectious Diseases Society of America.

Once an eligible neurologist has successfully registered for the Medicare EHR Incentive Program and met the meaningful use criteria using certified EHR technology, successful attestation is necessary to start earning incentive payments. To attest, eligible neurologists will need to have met meaningful use for a consecutive 90-day reporting period in the first year. For each additional year, eligible neurologists will have to meet meaningful use requirements for the entire year. Click here to begin the attestation process using CMS' web-based system.

Find more information regarding attestation.

Access the Meaningful Use Attestation Calculator and find out if you are meeting the program requirements.

The AAN hosted a webinar on February 15, "Ready, Set, Payment: Using Certified EHRs for Meaningful Use Payments". For more information and to purchase the recording, visit the 2012 Practice Management Webinar site.

You need to report Clinical Quality Measures (CQMs) through attestation.

CLICK HERE to view the 2012 eligible professional CQMs.

See page 7 of the December 2010 AANnews article discussing CQM reporting for neurologists. Although there are no neurology specific measures included, there are some measures that neurologists may want to consider reporting.

Eligible professionals must report from the table of 44 clinical quality measures which includes, 3 Core, 3 Alternate Core, and 38 additional CQMs.

• Core CQMs - EPs must report on 3 required core CQMs, and if the denominator of 1 or more of the required core measures is 0, then EPs are required to report results for up to 3 alternate core measures.
• EPs also must also select 3 additional CQMs from a set of 38 CQMs (excluding the core/alternate core measures). It is acceptable to have a '0' denominator provided the EP does not have an applicable population.

In sum, EPs must report on 6 total measures: 3 required core measures (substituting alternate core measures where necessary) and 3 additional measures. A maximum of 9 measures would be reported if the EP needed to attest to the 3 required core, the three alternate core, and the 3 additional measures.
It is acceptable to enter all 0’s in your denominator if you do not have an applicable population.  If you cannot find a single CQM that is relevant to your practice, you must report a “zero” on the denominator for all CQMs, meaning that zero patients met each CQM.  

Currently, the attestation process requires eligible neurologists to indicate that they agree with the following attestation statements:

• The information submitted for CQMs was generated as output from an identified certified EHR technology.
• The information submitted is accurate to the knowledge and belief of the EP or the person submitting on behalf of the EP
• The information submitted is accurate and complete for numerators, denominators, exclusions, and measures applicable to the EP
• The information submitted includes information on all patients to whom the measure applies.

The Centers for Medicare & Medicaid Services (CMS) considers information to be accurate and complete for CQMs insofar as it is identical to the output that was generated from certified EHR technology. Numerator, denominator, and exclusion information for CQMs must be reported directly from information generated by certified EHR technology. By agreeing to the above statements, the eligible neurologist is attesting that the information for CQMs entered into the Registration and Attestation System is identical to the information generated from certified EHR technology.

CMS does not require eligible neurologists to provide any additional information beyond what is generated from certified EHR technology in order to satisfy the requirement for submitting CQM information. Please note that quality performance results for CQMs are not being assessed at this time under the EHR Incentive Programs.

Some examples of clinical decision support rules specific to neurology are:

• Checking to see if patients with ischemic stroke are being treated with aspirin
• Checking to see if a patient with atrial fibrillation and a stroke is receiving warfarin for anticoagulation

These examples and other details were discussed in the February 2011 AANnews article (page 21).

Notable Differences between the Medicare and Medicaid EHR Incentive Programs.

Centers for Medicare & Medicaid Services (CMS) tip sheet for Medicare EHR incentive payments for eligible professionals.

Find your Regional Extension Center (REC).