Health Information Compliance Alert

You can collect incentive payments by participating with either Medicare or Medicaid -- not both.

CMS is still ironing out details of its electronic health record (EHR) bonus program, which could net an eligible professional (EP) $44,000 over a fiveyear period -- if you know the rules.

The agency’s proposal regarding the incentive program includes several important points that you should keep in mind as you create your EHR program, according to a Feb. 2 CMS-sponsored Physicians, Nurses, and Allied Health Professionals Open Door Forum.

“It’s important to note that EPs can only receive [EHR incentive] payments from either the Medicare or the Medicaid program " not both,” noted CMS’s Chris Gayhead during the call. “EPs can, however, make a one-time program switch for payment year 2014 or before. However, eligible hospitals receive payment from both programs as long as they meet the eligibility requirements.”

Hospital-based EPs, such as pathologists, anesthesiologists, or emergency physicians, who furnish substantially all of their Medicare services during the reporting period in a hospital setting (inpatient or outpatient) are considered hospital-based EPs and they are not eligible for the program, Gayhead said.

Plus: In order to be eligible for meaningful use payments from Medicare, an EP or eligible hospital must be a meaningful user of EHR technology, Gayhead said. The Recovery Act specifies three components of meaningful use: Using a certified EHR in a meaningful manner (for example, using e-prescribing), use of a certified EHR technology for electronic exchange of health information to improve quality of healthcare, and use of certified EHR technology to submit clinical quality and other measures, Gayhead said.

EHR incentive payments for EPs will operate according to the calendar year, Gayhead said, with the Medicare incentive program running from 2011 through 2016. EPs can receive a maximum of $44,000 over a five-year period. “To reach the maximum under Medicare, an EP must become a meaningful user no later than 2012,” she noted.

The start dates for payments under the program are staggered, with Medicare EPs having to wait until 2011 before the first incentive payments are issued.

The above requirements are based on CMS’s proposed rule.