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.

A reader posed the following question: What happens if a physician receives a Medicaid EHR incentive in 2011, no longer meets the 30% eligibility threshold for Medicaid in 2012 and therefore elects not to apply for any incentive that year, and then has to switch to the Medicare program in 2013 because his Medicaid volume is still too low to qualify under Medicaid? Below is a follow-up to a prior post, (“Switching Between Medicare and Medicaid Incentive Programs”), that provides the additional information needed to not only answer this particular question, but also to evaluate the financial impact of other scenarios in which a provider might skip years and/or switch between programs. 

Here are the rules regarding switching programs and skipping years:

• An EP can switch between programs only once after receiving his first incentive payment, and the switch must occur in 2014 or earlier.
• When an EP switches programs, he is “placed in the payment year he would have been in had he begun in—and remained in—the program to which he has switched.”
• Medicare and Medicaid treat skipping years differently. Medicare incentives require that payment years be consecutive—so while an EP can skip a year, if he does, he forfeits that year’s incentive permanently. Medicaid incentive payments, on the other hand, can be non-consecutive with no adverse impact on total available revenue.
• The last year that payments will be available also differs between the two programs. Under Medicare, no payments will be made after 2016, whereas EPs have until 2021 to earn incentives under Medicaid.
• Although an EP who switches to or from the Medicare program could—under certain circumstances—earn more than the total Medicare incentives ($44,000), in no cases would any EP be paid more than the maximum available under Medicaid ($63,750). 

To get back to the physician in the reader’s question, when he switches to the Medicare program after skipping 2012, 2013 would be considered (and paid as) his third payment year. 

Confused? To analyze the financial implications of switching programs and/or skipping a year under scenarios that might apply to your practice, make a chart and do the math—taking into account the above rules and the schedules of annual incentives.

In a previous Meaningful Use Monday we wrote about a bunch of the Meaningful Use 2011 statistics that were put out by ONC and CMS. I know that my readers love statistics and information about Meaningful Use. Carl Bergman sent me a PDF file that contained some really interesting data on Meaningful Use stage 1 in 2011. The first pages we basically covered in the previous post, but starting on about page 10 or so there are some more detailed numbers.

Take a look at let us know which numbers you find interesting and/or unique.

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.

Many physicians will be pursuing EHR incentives in 2012. Because meaningful use is not dependent upon G-codes, providers have been asking whether they need to continue putting “G-8553” on Medicare claims. The answer is YES—keep on G-Coding! 

Even though physicians who receive a Medicare EHR incentive are ineligible for an ePrescribing (MIPPA) incentive, they are still subject to future ePrescribing penalties. These penalties can be avoided by ePrescribing in 2012:

• Prevent the 2013 (1.5%) penalty – CMS is giving providers a second chance. If you failed to ePrescribe on the minimum 25 Medicare encounters in 2011, (which would have already protected you from the 2013 penalty), report G-8553 10 times between January 1 and June 30, 2012 on any Medicare claims. These claims don’t even have to be for the specified CPT “denominator” codes.
• Prevent the 2014 (2%) penalty – Report the G-code 25 times between January 1 and December 31, 2012. These claims must be associated with the specified CPT codes (typically E&M visits). 

If you are not pursuing meaningful use in 2012—or if you are, but for some reason fail to earn the incentive this year—you can still earn a 1% ePrescribing bonus under MIPPA if you report the G-Code on claims with the specified CPT codes 25 times between January and December . 

Like last year, there will be a process for requesting an exemption from the 2013 penalties, but surprisingly, the Proposed Rule did not include earning an EHR incentive as one of the justifications.

HITECH Answers recently posted a great post that gives a run down of the EHR Incentive program’s progress in 2011. Here’s their list with my own analysis and commentary of each point.

123,921 Eligible Professionals have registered for EHR Incentives, 15,255 have successfully attested to meaningful use in the Medicare program.
This seems like such a HUGE difference in numbers. That’s just over 12% of Eligible Professionals that registered attested to meaningful use. Does this mean that we’re going to see a tidal wave of meaningful use attestation in 2012? Possibly.

I believe that we’ll see more eligible professionals attesting to meaningful use in 2012. However, the question is how many of those other 108,666 will attest to meaningful use in 2012 and how many are like the Happy EMR Doctor who just registered to see the MU process. I wonder how many first hand meaningful use experiences by doctors will scare doctors away from MU attestation.

3.077 Eligible Hospitals have registered EHR Incentives and 604 of those have successfully attested to meaningful use.
This is almost 20% of hospitals that have registered that have attested to meaningful use. It’s not surprising that this number is a lot higher than eligible professionals. I still believe that the wave of meaningful use attestation will come from these other 2473 hospitals and probably many more that still haven’t registered. I haven’t seen a good number of how many hospitals are in the US. Does anyone know that number? The EHR incentive money that goes to hospitals will dwarf those of eligible professionals.

$2,533,689,145 has been paid out in Medicare and Medicaid Incentives.
$2.5 billion sent out in 2011. I just went back to the first time I tagged meaningful use on this site on April 3, 2009 (coincidentally I have 19 pages of 10 posts each tagged with Meaningful Use). Amazing to think that it’s taken basically 3 years to spend $2.5 billion on EHR.

277 hospitals have received payments under both Medicare and Medicaid and of those 12 were CAHs.
That’s about half of the hospitals that have attested to meaningful use under Medicare are also getting the Medicaid EHR incentive money as well.

22% of eligible professionals that have been paid EHR incentives are Family Practitioners and 20% are Internal Medicine.
I must admit that I would have thought that the percentage of family doctors that got paid EHR incentive money would have been a lot higher. I guess when you have so many other specialty areas I shouldn’t be that surprised. I also wonder why the internal medicine number is so high. These numbers actually make me believe that a lot of family practice doctors are sitting out when it comes to meaningful use.

41 States Medicaid programs were open for registration. Two additional States launched in January of 2012.
I wonder what’s holding back the other 7 states. From what I’ve seen all the states will eventually get there.

More than 1500 EHR products have been certified by ONC-ATCBs.
That’s a lot of EHR software. I still put the EHR company list at about 300 EHR vendors. 1500 includes multiple versions of the same software, partial EHR certification for products like data warehouses, ePrescribing, etc. The best thing that’s come from the ONC-ATCB program is that it has made EHR certification basically irrelevant in the EHR selection process. Every EHR vendor is certified now. This is much better than the false assurances that EHR certification provided before. I still dislike what EHR certification has done to the industry, but at least it’s not misleading doctors the same way it was before.

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.

Having just experienced the attestation process firsthand as I watched an SRS client successfully attest to meaningful use, I am happy to report that this part of demonstrating meaningful use is relatively easy—a bit tedious if you are attesting for multiple providers, but not at all difficult. CMS has created a user-friendly, web-based attestation system. Assuming that your EHR provides the information you need in a useful format, you have successfully met all the required measures, and you come prepared, there should be no reason to have an unsuccessful attestation.

Here are some tips that will ensure your success:

• Register in advance: Even though you can register as late as at the time of attestation, the combined task would be overwhelming—particularly if you are attesting “on behalf of” a provider. Registering in advance ensures that everything is up-to-date in NPPES and PECOS and that you have all the necessary information.
• Make sure that all measures have been met: If your EHR does not show the percentages for measures that have thresholds, do the math yourself to verify your success on each one. CMS offers a worksheet that you might find helpful for this purpose. Verify that you have also met all other (non-numerical) measures. If you fail to satisfy even one measure, do not attest now—go back and try another reporting period.
• Have documentation for each provider:
  - Registration confirmation page with registration ID#

  - Password

  - EHR certification number

  - Reporting period dates (make sure it covers at least 90 days)

  - Printout of all meaningful use measures: numerators and denominators, exclusions and reasons

    (when there is more than one possible reason)

  - Clinical Quality Measure report: numerators, denominators, exclusions

• Do not hit “Submit” until you have reviewed the “Attestation Summary” page: Double check your data. Make sure that you have said “yes” to all yes/no measures and that your numbers are entered accurately. The summary page does not display percentages, so you have to do the math yourself to be sure that you meet the thresholds.
• Submit attestation and print the “Submission Receipt” as confirmation: If you have done everything correctly it will state that “all measures are accepted and meet MU minimum standards.”

While not necessary, I highly recommend having a second person help you attest. A second set of eyes will shorten the time the process takes and will reduce the potential for errors in posting your data.

Anyone that is part of the healthcare IT and EMR world has to realize that we’re in a really incredible time for healthcare IT and EMR. There’s has never been more energy, excitement and actual investment in the Healthcare IT world than there is now. If you don’t believe me, buy your ticket to Las Vegas and attend HIMSS 2012 and I’m sure you’ll see what I mean. I have a feeling that HIMSS Las Vegas is going to be bigger than ever with more money flowing as well.

Just to provide a few examples of what’s happening, the prominent IT investor Esther Dyson has invested in 20 Health IT investments. That’s a whole lot of investment in healthcare IT. She obviously sees some real opportunities available at this time in health IT.

Another recent announcement was the recent batch of 15 Rock Health Startup companies. This is just one of at least 3 or 4 health focused incubators out there. Plus, the latest batch of health IT startup companies from Rock Health even has Neil Versel singing their praises after a previous not so glowing review of the health startup incubator (or health accelerator if you prefer).

One other thing that is easy to underestimate is the value that the US government is putting on supporting healthcare innovation through entrepreneurship. Normally I’m as skeptical as anyone in putting any sort of faith in government to produce results. I still think they have their hands tied in a lot of things, but I give a lot of credit to Aneesh Chopra, Todd Park and Farzad Mostashari for doing their very best to kick against the challenges of big government while enabling health entrepreneurs to be successful.

Priya Ramachandran wrote about an example of one initiative the government is putting forward to help entrepreneurs: Access to Public Health Data. Every time I hear someone talk about the data that’s available from these public repositories of health data, the entrepreneur inside of me kicks in with ideas on how to use that data for good.

It is a really tremendous time to be an entrepreneur in healthcare. I do think we still need a better platform for health IT startups to launch their products and get funding. I have a few ideas I’m working on in this regard. More on this in the future.

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.

Meaningful Use Monday posts have delved into the nitty-gritty details of meaningful use, but I know that there are many providers and practice administrators who are still trying to wrap their arms around the basics of the EHR Incentives Program. CMS has just condensed the enormous amount of information available on its website into one handy, presentation-style document that explains the program.

Called “An Introduction to the Medicare EHR Incentive Program for Eligible Professionals” (PDF), its URL identifies it as a “Beginners Guide”. (They could just as easily have named it “Meaningful Use for Dummies”, trademark infringement issues notwithstanding.) Although it is 85 slides long, the presentation is succinct, easy-to-navigate, and covers a full range of topics—including eligibility, program options, meaningful use measures, registration, attestation, other resources, etc.

Check it out! …And for more information, I invite you to browse through the comprehensive Meaningful Use Resource Center on the Government Affairs section of our company’s website (www.srssoft.com).

Wishing everyone Happy Holidays and a “Meaningful” New Year!
Lynn

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.

HHS recently announced the postponement of Stage 2 Meaningful Use to 2014. The only providers who are in a position to act on this “opportunity” are those who have not yet, but still could, attest to meaningful use in 2011—but, a word of caution before you rush to attest in 2011. 

The HHS announcement “encourages any providers who have been waiting until 2012 to attest to Stage 1 meaningful use now. ….Those providers who first attest in 2011 can get three payment years for meeting the Stage 1 expectations, while those first attesting in 2012 can only get two payment years under Stage 1 criteria.” 

True. However, you must carefully weigh the benefit, (earning the $8,000 third incentive payment under the rules of Stage 1 instead of those of Stage 2), against the cost, (the permanent loss of your 2011 Medicare ePrescribing bonus money). Remember, you cannot receive incentive payments under both programs during the same year, so you maximize your total reimbursement by collecting the 1% ePrescribing bonus this year and waiting just 3 months to begin earning the $44,000 in EHR incentives over the next 5 years. There is no universally right or wrong strategy—just do the math and analyze the trade-off before making a decision.

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.

Meaningful Use penalties—or to use the politically correct word, “adjustments”—are scheduled to begin in 2015 for providers who are not meaningful users of certified EHR technology by 2014. There’s something about the prospect of incurring a revenue reduction that seems to evoke a visceral response among providers—even among those who do not find the potential incentive money motivating.

Here’s what you need to know about the penalties:

1) Penalties apply to Medicare only.
- Adjustments will be applied as a percent of Medicare Part B Professional Fee Schedule Charges.
- They are scheduled to begin in 2015, and continue as follows:
2015: 1%
2016: 2%
2017: 3%
2018 and 2019: may increase 1%/year, at the discretion of the Secretary of HHS.

2) There has been speculation by some industry pundits that the penalties will be delayed or not implemented at all, but to rely upon that as a given would be a mistake.

3) There are no penalties associated with the Medicaid program—adjustments do not apply to Medicaid revenue. Pursuing the EHR incentives as a Medicaid provider, however, does not totally insulate a physician from the penalties. If a Medicaid provider does not become a meaningful user by 2014, the revenue he/she generates under Medicare would be subject to the adjustments above.

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.

EPs cannot receive EHR incentives from both Medicare and Medicaid in the same year—they must choose between the two, even if they are eligible under both programs. As discussed in a prior Meaningful Use Monday post, Medicaid is typically the EHR incentive program of choice for EPs who have a sufficiently large Medicaid volume. 

But providers must re-qualify annually, so what happens if the participating provider’s Medicaid volume drops below the 30% (or 20% peds.) threshold in a future year, making him/her no longer eligible for that program? What about an EP who initially participates as a Medicare provider, but subsequently becomes eligible for the more generous Medicaid program? As the first EHR Incentive Program participants approach year 2, they need to understand their options in this regard. 

The rule is as follows:  An EP may switch from one program to another, but only one time after receiving his/her first EHR incentive payment, and only for a payment year before 2015.  

Note: In case you are doing the math and calculating how you could game the system to increase your potential revenue, the rule goes on to say that under no circumstances can an EP’s total incentives exceed the total available under Medicaid, (i.e., $63,750).