Monday, January 24, 2011

Obtaining Meaningful Use Stimulus Payments

Many clinicians and hospitals have asked me about the exact steps to obtain stimulus payments.

On January 3, 2011, CMS began registering clinicians for participation in meaningful use programs.    Every region of the United States has Regional Extension Centers which can help answer any questions. Here's an overview of the steps you need to take.

1.  Choose between Medicare and Medicaid programs.  If you qualify, Medicaid offers greater incentives and does not require you to achieve meaningful use before stimulus payments begin.
a.  To qualify for Medicaid, 30% of your patient encounters must be Medicaid patients. (20% for pediatricians)
b.  To qualify for Medicare, keep in mind that meaningful use payments are made at 75% of Medicare allowable charges for covered professional services in the calendar year of payment, per the payment maximums below:

Year 1  $18,000
Year 2  $12,000
Year 3  $8000
Year 4  $4000
Year 5  $2000

Thus, a total of $44,000 is available at maximum, but could be less if your allowable Medicare charges are less than

Year 1 $24,000
Year 2 $16,000
Year 3 $10,667
Year 4 $5333
Year 5 $2667

Also, if 90% of your Medicare charges take place in inpatient or emergency department locations, you cannot qualify for the meaningful use program.  This means that emergency physicians, anesthesiologists, radiologists, and pathologists generally cannot participate.  Some professionals may also find that they do not have enough Medicaid or Medicare charges to benefit from either program.

2.  Once you've chosen Medicare or Medicaid, you must register to participate
a.  You need a National Provider Identifier and password.   If you do not have one, go to the NPPES website.
b.  One you have a password, go to the CMS EHR Incentives Website and register as an eligible professional
c.  Two valuable resources include the Registration User's Guide and the CMS overview of the EHR incentive programs.

3.  The Meaningful Use demonstration period is 90 days beginning January 1, 2011 so the first date that you can attest to meaningful use of Certified EHR technology is April 1, 2011.   Note that the EHR technology you use must be certified by the time you attest.  You can begin your meaningful use reporting period using uncertified EHR technology as long as it is certified by the end of your reporting period.

Medicare payments will begin in May.  Medicaid payments are administered by states and will begin when state governments are ready to administer the program.  Some states are ready now and others will not be ready until August.  Remember that Medicaid payments start before meaningful use is achieved so there is no need to wait for meaningful use measurement and attestation for the Medicaid program.

Hospital requirements are similar
a.  First, you must locate the following, which your Revenue Cycle staff are likely to have:
CMS Identity and Access Management (I&A) User ID and Password.
CMS Certification Number (CCN).
National Provider Identifier (NPI).
Hospital Tax Identification Number.
b.  Go to the CMS EHR Incentives Website and register as an eligible  hospital
c.  The Hospital Registration User's Guide is a valuable resource

Here's a summary of the key dates for the program:

January 1, 2011 – Reporting year begins for eligible professionals.
January 3, 2011 – Registration for the Medicare EHR Incentive Program begins.
January 3, 2011 – For Medicaid providers, states may launch their programs if they so choose.
April 2011 – Attestation for the Medicare EHR Incentive Program begins.
May 2011 – EHR Incentive Payments expected to begin.
July 3, 2011 – Last day for eligible hospitals to begin their 90-day reporting period to demonstrate meaningful use for the Medicare EHR Incentive Program.
September 30, 2011 – Last day of the federal fiscal year. Reporting year ends for eligible hospitals and CAHs.
October 1, 2011 – Last day for eligible professionals to begin their 90-day reporting period for calendar year 2011 for the Medicare EHR Incentive Program.
November 30, 2011 – Last day for eligible hospitals and critical access hospitals to register and attest to receive an Incentive Payment for Federal fiscal year (FY) 2011.
December 31, 2011 – Reporting year ends for eligible professionals.
February 29, 2012 – Last day for eligible professionals to register and attest to receive an Incentive Payment for calendar year (CY) 2011.

I hope this clarifies your next steps.   May your stimulus funds flow quickly in 2011!


Unknown said...

I would like to debate the statement that radiologists generally cannot participate in Meaningful Use incentives.

Since POS 22, Outpatient Hospital is part of the Eligible Professional bucket, the ACR (American College of Radiology) expects up to 90% of radiologists, including hospital-based radiologists, to qualify as Eligible Professionals. To say it another way, it is expected that most hospital-based radiologists have a POS 22 patient load of > 10%, allowing them to qualify as an EP.

Since EPs cannot qualify for CMS incentives using Inpatient certified technology, as a CIO how are you going to help your radiologists qualify for incentives? This is an interesting question for medical imaging since its common for hospitals to own the RIS / PACS.

KMS said...

I agree with Tom regarding radiologists eligibility for meaningful use. Majority of radiologists, even in hospital based practice, will qualify as EPs as per CMS final rule.

Here is blurb from ACR's summary on CMS final rule:

Eligibility: All physicians are eligible EXCEPT for those "hospital-based" physicians who provide >90% of their total Medicare (or Medicaid) services in POS Codes 21 (inpatient hospital) or 23 (ER hospital) locations. The difference in the Final Rule is that POS Code 22 (outpatient hospitals) was removed from the definition of “hospital-based,” per the tax extenders bill language from earlier this summer. One interesting note: CMS is expecting that only 14% of all Medicare physicians will be considered "hospital-based" and therefore ineligible.

Here is link to a summary of how MU applies to radiologists from American College of Radiology. Another good link for more information is

I would also like to know, how you are preparing/helping radiologists at BI qualify for incentives?

Anonymous said...

Thank you for the opportunity to comment. I wanted to chime in about your expectation as to which specialists will be ineligible for the Medicare version of the EHR Incentive Program for EPs.

The two previous comments are generally correct. Most practicing radiologists will be eligible for the Medicare version of the EHR Incentive Program for EPs. The vast majority of practicing radiologists –- even those in hospital-contracted practices and AMCs –- do not provide 90 percent or more of their services in exclusively inpatient and ER hospital settings as determined by the POS code (21 or 23) on claims.

Many anesthesiologists and pathologists are essentially in the same boat, even though those two specialties were singled out as examples of "hospital-based" professionals in the original legislative language. In reality, due to the use of POS codes on claims to determine eligibility, only Emergency Physicians and Hospitalists are going to be deemed "hospital-based" en masse.

I would suggest that advisors on ONC’s federal advisory committees reach out to national groups like the American College of Radiology, American Society of Anesthesiologists, and College of American Pathologists to revisit what appears to be a key misunderstanding underlying the recommendations of the HIT Policy Committee and HIT Standards Committee.

Anonymous said...

We attested for Medicare in the first few days. We were told we were approved but have seen no payments. Does anyone know where we could go to check on the status of our attestation and payement?