Medicare EHR Incentive Program
Current NewsMeaningful Use Stage 2 Final Rule Released
Deadline Quickly Approaching to Start Earning $44,000!
What is the Medicare EHR Incentive Program?
The Medicare (and Medicaid) EHR Incentive Program will provide incentive payments to eligible professionals, eligible hospitals and critical access hospitals (CAHs) as they adopt, implement, upgrade or demonstrate meaningful use of certified EHR technology.
Through successful reporting over a five-year period, neurologists are eligible for up to $44,000 through the Medicare incentive program, and up to $63,750 over a six-year period through the Medicaid incentive program.
Participating neurologists must implement and demonstrate meaningful use through certified EHR technology, as defined by the Office of the National Coordinator for Health Information Technology (ONC).
Key points of Stage 1 of Meaningful Use include:
- Physicians have to meet 15 core objectives and choose an additional five objectives from a menu of 10 options.
- Physicians must report on three core clinical quality measures (related to blood pressure management, tobacco use and weight) as well as three additional quality measures that they may choose from a list of 38.
Medicare EHR Incentive Program Payment Schedule:
|Start in 2011||18,000||12,000||8,000||4,000||2,000||0||44,000|
|Start in 2012||18,000||12,000||8,000||4,000||2,000||44,000|
|Start in 2013||15,000||12,000||8,000||4,000||39,000|
|Start in 2014||12,000||8,000||4,000||24,000|
|Start in 2015||0||0||0|
New: CMS has finalized the Physician Quality Reporting System (PQRS)-Medicare EHR Incentive Pilot Program. This voluntary program requires participants to report clinical quality measures (CQMs) for a full 12-month calendar year (regardless of the eligible professional's year of participation in the Medicare EHR Incentive Program).
Those who wish to participate in this pilot program will be able to indicate within the EHR Incentive Program attestation module their intent to fulfill the Meaningful Use (MU) objective of reporting CQMs by participating in the pilot. It will allow those who are participating in both MU and PQRS to report their clinical quality measures once.
Those who do not participate will continue to report their Meaningful Use CQMs through attestation. The purpose of this pilot is to move towards integration of reporting on quality measures under the PQRS with the reporting requirements of the 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
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
- Make sure you are eligible for the Medicare EHR Incentive Program.
- 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.
- Use certified EHR technology.
- Successfully demonstrate meaningful use for 90 consecutive days for your first year of participation (a full year in each subsequent year)
- 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.
Access the Meaningful Use Attestation Calculator and find out if you are meeting the program requirements.
You need to report Clinical Quality Measures (CQMs) through attestation.
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).
Eligible providers, eligible hospitals, and critical access hospitals attesting in either the Medicare or Medicaid Electronic Health Record (EHR) Incentive Program may be subject to an audit. The Centers for Medicare & Medicaid Services (CMS) and its contractor, Figliozzi and Company, have begun performing audits for providers who are participating in the Medicare EHR Incentive Program (or those dually eligible for both Incentive Programs). Post-payment audits have been performed since 2012, while pre-payment audits began in 2013 for those submitting attestations beginning in January 2013.
States will be performing audits on Medicaid providers participating in the Medicaid EHR Incentive Program.
Available resources include:
- Find your Regional Extension Center (REC).
- Medicare EHR Incentive Program Registration User Guide for Eligible Professionals
- Medicaid EHR Incentive Program Registration User Guide for Eligible Professionals
- Medicare EHR Incentive Program Attestation User Guide for Eligible Professionals
- Medicare and Medicaid EHR Incentive Programs Stage 2 Toolkit