Wednesday, May 25, 2011

Meaningful Use Payments Arrive

HITECH Incentive payments began on May 19, four weeks after attestation for Meaningful Use became available. 

On May 19, BIDMC received the following electronic funds transfer from CMS/Medicare:


BIDMC was the first hospital in the country to attest to meaningful use and received payment from CMS on the first day of stimulus disbursements.   Hospital payments start with a $2 million base payment.  Per the CMS FAQ 

"Eligible hospitals and CAHs will receive an initial payment and a final payment. Eligible hospitals and Critical Access Hospitals that attest in April can receive their initial payment as early as May 2011. Final payment will be determined at the time of settling the hospital cost report."

Although we received an initial $2 million dollar payment, we have not received information about the final payment calculation or timing.

Some have worried that attesting early will create a timeline for stage 2 that is challenging to meet i.e.

Standards Committee work for stage 2 will be done by September 2011
ONC proposed regulations will be drafted in the Fall, released in December and will become final in mid 2012
The Stage 2 meaningful use demonstration period begins October 1, 2012

The likelihood that regulations can be transformed into working, implemented software by October 1, 2012 is slim.

Hence the HIT Policy Committee will likely recommend that Meaningful Use Stage 2 be deferred a year, meaning that the demonstration period for those who attest to stage 1 in 2011 will be moved to October 1, 2013.

Based on everything I know, here's the workplan I'd recommend for IT departments
1.  In 2011, update your purchased products as needed to implement meaningful use versions
2.  In 2011, if your systems are built rather than bought (or are a combination of the two), use the CCHIT EACH program to certify your site as needed for hospital and ambulatory certification criteria.
3.  In 2011, educate your clinicians and measure meaningful use metrics for a 90 day demonstration period.  Note that this can be done in parallel with certification, since systems only need to be certified by the end of the demonstration period
4.  In 2011, collect your initial meaningful use payments
5.  In 2011, work on X12 5010 for the January 1, 2012 deadline
6.  In 2011, begin ICD10 planning for the October 1, 2013 deadline.   I believe this deadline will be extended.
7.  In 2012,  plan on beginning your Meaningful Use stage 2 measurement period on October 1, 2013.

A lot going on in parallel, but by taking it one day at time, step by step, it's doable.


terry said...

My understanding from following the HIT Policy Committee's conversation related to a possible delay in the stage 2 objectives by one year would be that those EPs who demonstrate meaningful use via the Medicare path in 2011 would in effect miss the 3rd year of the incentive program. They could demonstrate meaningful use in 2012, but would not be permitted to use the stage 1 objectives for a third reporitng year in 2013. John, is this your understanding as well?

John Halamka said...

The payments to Eligible Physicians will take place per the already announced payment scheduled. This would not be changed.

Meaningful Use Stage 1,2,3 timelines are decoupled from payment schedules.

The proposal is that those who attest in 2011, would not need to attest again until 2014.

There would be no penalties for doing this.

terry said...

Thanks, I misinterpreted the proposal. To be clear if stage 2 is delayed one year and I have attested in 2011, my next attestation would be in 2014 for stage 2 and if successful I would receive $12,000. As 2016 is the last year to receive a Medicare payment, the early adopters only miss the $2,000 year 5 incentive payment. If I had waited until 2012 to start I would attest to stage 1 in 2012 and 2013 receiving $18,000 and $12,000 respectively assuming I was successful, then move on to stage 2 in 2014. I did not realize an EP could "skip" a reporting year (or 2 in the first scenario)and later recoup the incentive.

John Halamka said...

My understanding is that the payment schedule will be

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

The proposal is to move the stage 2 measurement period to year 3 for professionals who attest to stage 1 in 2011, not change the payment schedule.

Anonymous said...

There is some conflicting guidance out there regarding the issue of 2011 meaningful users missing a 2013 payment if Stage 2 is delayed. Interestingly enough, the conflict stems from two statements made by Dr. Tang. On May 3, he indicated that 2011 meaningful users would miss a payment year (yes a payment year) if Stage 2 is delayed until 2014. However, Dr. Tang later stated (at the most recent HIT Policy Committee meeting) that 2011 attesters would have three years in Stage 1 in the event that Stage 2 is delayed. I suppose the June 8 HIT Policy Committee meeting with shed some light on this.

John Halamka said...

Here's the language that will be discussed at the next policy committee meeting

"For EPs who attest in 2011 ONLY, they would qualify
under existing stage 1 criteria through 2013 (ie year 3)"