EHR Incentive Program
Earn incentive payments and avoid penalties by participating in the Medicare Electronic Health Records (EHR) Incentive Program.
- The Centers of Medicare and Medicaid Services (CMS) has released the proposed rule for Stage 3 meaningful use of electronic health records (EHR). Along with the proposed rule, CMS and the National Coordinator for Health IT (ONC) unveiled its proposed 2015 edition for EHR Certification criteria.
- Read the AAN's comment letter regarding the proposed rule for Stage 3 meaningful use.
- Program basics
The Medicare and Medicaid Electronic Health Records Incentive Programs provide incentive payments for demonstrating meaningful use of EHR technology.
- Neurologists are eligible for up to $44,000 through the Medicare program and up to $63,750 over a six-year period through the Medicaid program.
- Meet 14 core objectives and choose 5 objectives from a menu of 10.
- Report 6 clinical quality measures from a list of 44 options.
- Medicare payment schedule
- Review the Medicare Payment Schedule
- Medicaid Payment Schedule
- Review the Medicaid Payment Schedule
Eligible professionals (EP) include:
- Doctor of medicine or osteopathy
Eligible Hospitals include:
- "Subsection (d) hospitals" paid under the Inpatient Prospective Payment System (IPPS)
- Critical Access Hospitals (CAHs)
- Medicare Advantage (MA-Affiliated) Hospitals
For more information visit the CMS website.
- Medicare patient volume
Consider patients from all payers to be counted in both the numerator and denominator.
The maximum incentive payment, based on 75 percent of allowed charges, comes after accumulating $24,000 in Medicare charges.
There is a minimum number of patient volume for Medicaid, but not Medicare:
- A minimum 30 percent Medicaid patient volume
- A minimum 20 percent Medicaid patient volume, and is a pediatrician
- Earning incentive payments
- Attesting for meaningful use
- Successful attestation is necessary to start earning incentive payments.
- Meet meaningful use for a consecutive 90-day reporting period in the first year.
- For each additional year, meet meaningful use requirements for the entire year.
- Attestation must occur through the CMS web-based attestation system.
- Access the Meaningful Use Attestation Calculator.
Contact the EHR Information Center at 1-888-734-6433 (open Monday through Friday from 7:30 a.m. -6:30 p.m. CT) if you need assistance with any registration and attestation system inquiries.
- Clinical quality measures
Beginning in 2014, reporting of CQMs changes for all providers regardless of whether they are participating in Stage 1 or Stage 2 of meaningful use.
- Eligible professionals must report on 9 of 64 approved CQMs (CMS has made recommendations for core CQMs for both the adult population and the pediatric population)
- All Medicare-eligible providers beyond their first year of meaningful use must electronically report their CQM data to CMS.
View the annual update of the 2014 electronic clinical quality measures.
- Clinical decision support
Some examples of clinical decision support rules specific to neurology are:
- Checking if patients with ischemic stroke are being treated with aspirin
- Checking if a patient with atrial fibrillation and a stroke is receiving warfarin for anticoagulation
- EHR Incentive program resources
- Meaningful use stage 2
Stage 2 becomes effective in 2014. This is for those who began participating in 2011 or 2012.
Under Stage 2 you must:
- Meet 20 total objectives: 17 core objectives and three menu objectives from a list of six
- Report on 9 out of 64 total CQMs
- Select CQMs from at least three of six key health care policy domains:
- Patient and Family Engagement
- Patient Safety
- Care Coordination
- Population and Public Health
- Efficient Use of Healthcare Resources
- Clinical Processes/Effectiveness
For more information, check the Stage 2 Toolkit.
- Information on EHR Incentive Program Audits
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.
States will be performing audits on Medicaid providers participating in the Medicaid EHR Incentive Program.
Available resources include:
- Hardship Exceptions
Hardship exceptions are granted under specific circumstances as determined by CMS. Hardship application period to avoid 2016 payment adjustment closed July 1.
Eligible professionals can apply for hardship exceptions in the following categories:
- Infrastructure: Must demonstrate that you are in an area without sufficient internet access or face insurmountable barriers to obtaining infrastructure (e.g. lack of broadband)
- New Eligible Professionals: Newly practicing EPs can apply for a 2-year limited exception to payment adjustments. For example, a newly practicing neurologist who begins in CY 2015 would receive an exception to penalties in 2015 and 2016, but would need to begin demonstrating MU in CY 2016 to avoid a penalty in 2017.
- Unforeseen Circumstances: Examples include natural disaster or other unforeseeable barrier.
- Lack of Patient Interaction:
- Lack of face-to-face or telemedicine interaction with patients
- Lack of follow-up need with patients
- Multiple Locations: Lack of control over the availability of certified EHR technology for more than 50% of patient encounters.
- NEW! 2014 EHR Vendor Issues: The EP's EHR vendor was unable to obtain 2014 certification or the eligible professional was unable to implement MU due to 2014 EHR certification delays.
Access the CMS Payment Adjustments & Hardship Exceptions website for more information and to access the EP Hardship Exception Application.