More Meaningful Use Clarifications and Maximizing EHR (ARRA) and ePrescribing (MIPAA) Incentives

I love the smart readers from this site. They always keep me in line and do a good job clarifying the details of meaningful use for me and you. A few such comments were made on my years for meaningful use post. I thought they were worth sharing since I know that many of you don’t go back and read the great comments people make on my posts (I’ll forgive you for now).

Lynn Scheps from SRSsoft wrote the following comment about a benefit to not showing meaningful use in 2011 and electing to wait until 2012. It’s a way to maximize your incentive money. Although, you will need to implement your EHR quickly to maximize them. Here’s Lynn’s comment:

There is an additional benefit to electing 2012, instead of 2011, as an EP’s first EHR incentive payment year (an unintended consequence of the legislation, no doubt!) In that case an EP can still collect the ePrescribing (1%) bonus for 2011, while potentially qualifying for the maximum ($44K) in EHR incentives. An EP cannot collect under both MIPPA (ePrescribing) and ARRA (EHR incentives) during the same reporting period.

There was also some discussion on the idea of skipping a year of meaningful use and the impact of such a choice. Lynn offers the following comments in response to skipping a year of meaningful use.

In response to Wes Kemp’s comment about the 90-day reporting period and the consequences of skipping years, note that the rules differ under Medicare and Medicaid. Under Medicare, 90 days is sufficient for an EPs FIRST PAYMENT YEAR, regardless of what calendar year that is. For all subsequent payment years, the EP must report on the full year. After the first payment is received by the EP, every year is considered a payment year, whether or not an incentive is earned. So, while an EP can skip a year, he/she forfits the money for that year. Payment amounts are governed by the year in which they are received, not by what year it is for the EP. (p. 44319 of Final Rule.)

Wes Kemp also offered some insights on the Medicaid program and its requirements for meaningful use, attestation and it highlights some interesting differences between the Medicaid and Medicare EMR stimulus (I’ll admit that I don’t know as much about the Medicaid side):

Yes, requirements are more relaxed under Medicaid, than Medicare for MU incentives. My posts relate to MediCAID, since that is my current client’s need. So, with that in mind:

Yes, John, under MediCAID, an EP can attest and then apply for the funds the very next day – no reporting period / requirements in first year. 90 consecutive days reporting in year 2 is required, and full-year reporting for all subsequent participation years.

For subsequent years, the targets are clear enough that EPs will be aware of whether or not they have complied just by reading the data before submitting it. The measures are listed, from which a certain number are selected to report. The denominator / numerator are clearly defined…as are the % targets for each measure. So an EP is able to monitor and strive to achieve the required % of encounters counseled about smoking, for example.

Indeed there are items still to be defined. Optometrists are not specifically included as EPs under the MediCAID MU rules – however, I have been told more than once by ONC that for FQHCs they will be, this is not yet written anywhere that I am aware of. Also, for larger clinics, tracking all the MU measures by EP will require significant effort; especially if EPs come & go during the reporting year.

I think I might invite smart people like Lynn and Wes to do a regular post talking about more details of meaningful use. There’s so many questions still out there about meaningful use. Some we know the answer to, but there’s a lot of things we still don’t understand. Hopefully together we can share what we learn about meaningful use and the EMR stimulus.