Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.

Year 1 of the EHR Incentives program is almost history. Do you have a plan for 2012? What you do next year depends on what you did this year. 

If you did not pursue meaningful use in 2011—and many Medicare providers did not, either because they were not ready yet or because they opted to earn the ePrescribing incentive under MIPPA instead—it is now time to focus on meaningful use. You can choose any 90-day reporting period in 2012 starting as late as October 3^rd, but it would be wise not to leave it to the last minute.

If you successfully attested to meaningful use in 2011, your reporting period for the second year’s incentive is a full calendar year. Regardless of which 90-day period you chose to report on for 2011, in 2012 you will report from January 1 to December 31. Incentives are tied to calendar years, so even if you completed your 2011 reporting period in September, your next period does not begin until January. Take a break from reporting, but do not abandon your meaningful use workflow.

For EPs who participate under the Medicare program, the 5 years of incentive payments must be continuous in order to earn the full $44,000 in incentives. Once you receive your first payment, skipping a subsequent year, (i.e., failing to demonstrate meaningful use), while permissible, will mean that you forfeit the payment associated with that calendar year. 

For EPs who receive a 2011 Medicaid incentive for “Adoption, Implementation, or Upgrade,” 2012 will require the demonstration of meaningful use. Since it will be your first year of meaningful use, you will only be expected to report on a 90-day period, and that period can occur any time during the year. Medicaid participants are eligible for 6 incentive payments—as opposed to 5 for Medicare providers—and unlike Medicare, the years do not have to be consecutive, as long as they are all completed by 2021. 

It’s time to start thinking about 2012.