While we often mention the government incentives offered for meaningful use compliance, we frequently get questions about the specifics of each program, who is eligible for which incentives, and when the actual checks will arrive in the mail. Admittedly, it can be somewhat mystifying, so here we will help to lay out what to expect.
Let’s start with the basics:
– Which program do I qualify for?
By now, you likely know that the Health Information Technology for Economic and Clinical Health (HITECH) Act, enacted as a part of the American Reinvestment and Recovery Act of 2009, promises financial incentives for hospitals and clinicians who meet the requirements for meaningful use. There are two separate programs under which institutions and "eligible providers" (EPs) can qualify for a payout: Medicare and Medicaid. We won’t cover the hospital programs here, but will focus just on the incentives for EPs.
First, under the Medicare Program, any doctor (which includes any MD or DO, dentist, podiatrist, optometrist, or chiropractor) who treats Medicare patients can qualify as an eligible provider. EPs who adopt a certified electronic health record and comply with an extensive set of rules defining how they use it will receive up to $44,000 in increased Medicare payments over a 5-year period.
Below, we will discuss in detail how the money is allocated, but it is worth noting here that EPs who do not charge a defined minimum annual dollar amount to Medicare will not receive the full incentive. Instead, they will receive a percentage of their total billing.
Also worth noting is the absence of care extenders such as nurse practitioners (NPs) and physician assistants (PAs) from the list of eligible providers under the Medicare program. The Medicaid program is quite different.
Fewer providers will qualify for the Medicaid incentive, but there is greater financial benefit and flexibility for those who do fall under this program. To be eligible, any physician (MD or DO), nurse practitioner, certified nurse-midwife, or dentist must have a minimum of 30% Medicaid patient volume (or 20% if the provider is a pediatrician). Physician assistants can also be eligible if he or she provides care in a federally qualified health center or rural health clinic that is led by a physician assistant.
The maximum financial incentive is raised to $63,750; but unfortunately, the Medicaid incentive program is not available in every state. Currently absent from the list of participating states are Hawaii, Minnesota, Nevada, New Hampshire, and Virginia. One additional note: A provider eligible under both Medicare and Medicaid will need to choose just one program in which to participate, but may switch once during the total duration of the incentive initiative.
– How does the money get paid out?
As mentioned above, the Medicare incentive program pays out a maximum of $44,000 over a 5-year period. It is not divided equally over each year, and several factors may affect the total amount.
First, only providers who adopt a certified EHR and begin attesting by the 2012 incentive year can receive the maximum benefit. To receive any benefit at all, an EP must begin attesting by 2014. To give a more tangible example, if one were to successfully attest starting in 2012 and continue to successfully attest every year, he or she would receive the following annual payments: $18,000 in 2012, $12,000 in 2013, $8,000 in 2014, $4,000 in 2015, and $2,000 in 2016, for a total of $44,000.
If he or she were to delay attesting by just 1 year, the maximal payout amount would decrease to $39,000, as the first payment drops to $15,000 and final year incentive is lost.
As mentioned earlier, any EP not meeting a minimum threshold in Medicare charges will not be eligible for the full incentive, but instead will receive a percentage of their billing. For example, in year 1, any EP not submitting at least $24,000 in Medicare charges will receive 75% of their billing as their incentive.
Thankfully, a provider need not wait to attest until that $24,000 is reached. Medicare will hold the payment until the threshold is met or until the end of the calendar year, whichever is first. At that point, an EP can expect to see the incentive check within 4-8 weeks, according to CMS statements.
The Medicaid program works a bit differently. First, the EP may receive an incentive payment in year 1 of the 6-year attestation period for simply adopting, implementing, or upgrading to a certified electronic health record. (Following the initial year, that provider will need to follow the same guidelines outlined under the Medicare program).