Electronic Health Record (EHR)
Incentive Payment Requirements Defined by CMS
The Centers for Medicare & Medicaid Services (CMS) has finalized criteria for certified Electronic Health Record (EHR) systems and use of the technology in order to qualify for incentive payments under Medicare and Medicaid.
The guidance is spelled out in a July 16, 2010, final rule that implemented provisions of the American Recovery and Reinvestment Act of 2009 (Recovery Act).
The Medicare EHR incentive program offers bonus payments to eligible medical professionals including physicians and hospitals who meet newly defined standards for being "meaningful users" of certified EHR technology. The incentives are intended to encourage Medicare providers to adopt, implement, upgrade, or expand use of certified EHR technology.
The standards for achieving meaningful use of EHR systems are intended to improve health care quality, efficiency, and patient safety.1 To accomplish this, CMS has introduced a phased approach for demonstrating meaningful use of EHR technology.
In general, Stage 1 criteria will require:
- Electronically capturing health information in a coded format;
- Using that information to track key clinical conditions and communicating that information for care-coordination purposes;
- Implementing clinical decision-support tools to facilitate disease and medication management;
- Using EHRs to engage patients and families and to report clinical quality measures and public health information.2
The reporting requirements vary based on when a physician begins reporting results to CMS. Criteria for demonstrating meaningful use of EHR technology during the program's Stage 2 and 3 phases has yet to be determined and will be defined in future regulatory guidance.3
Starting in 2011, eligible professionals can qualify for up to $44,000 over five years under Medicare or up to $63,750 over six years under Medicaid. Eligible professionals who are not "meaningful users" of EHRs will face reduced Medicare payments beginning in 2015. There are no payment adjustments that will be associated with not participating in the Medicaid incentive program. Eligible health care providers can register for the programs starting January 3, 2011.4
Those who meet the eligibility requirements for both the Medicare and Medicaid incentive programs can participate in only one program, and must designate which one. After their initial designation and receipt of an incentive payment, eligible providers are allowed to change their program selection only once and only for a payment year prior to 2015.
Reporting Period: For the first year an eligible provider applies for and receives an incentive payment, the EHR reporting period will be 90 days for any continuous period beginning and ending within the calendar year (i.e., EHR reporting period can be January 1, 2011 to April 1, 2011, or March 13, 2011 to June 11, 2011, etc.). For every year after the first payment year, the EHR reporting period will be for the entire calendar year.5
Additional information regarding the incentive programs and a copy of the CMS Final Rule is available at www.cms.gov/EHRIncentivePrograms/.
1 CMS Fact Sheet. "CMS Finalizes Definition of Meaningful Use of Certified Electronic Health Records (EHR) Technology." July 16, 2010.
2 American Medical Association. Overview of Medicare Incentives in the Centers for Medicare and Medicaid Services (CMS) Final Rule on Meaningful Use of Certified Electronic Health Records. Available at www.ama-assn.org/ama1/pub/upload/mm/472/ehr-medicare-incentive-summary.pdf. Accessed on Dec. 7, 2010.
3 CMS Fact Sheet. "CMS Finalizes Definition of Meaningful Use of Certified Electronic Health Records (EHR) Technology." July 16, 2010.
4 CMS. "Overview: EHR Incentive Programs." Available at www.cms.gov/EHRIncentivePrograms/ Accessed Dec. 13, 2010.
5 American Medical Association. Overview of Medicare Incentives in the Centers for Medicare and Medicaid Services (CMS) Final Rule on Meaningful Use of Certified Electronic Health Records. Available at www.ama-assn.org/ama1/pub/upload/mm/472/ehr-medicare-incentive-summary.pdf. Accessed on Dec. 7, 2010.
Coverage policies may vary by insurer or even between plans offered by the same insurer. This information is presented for informational purposes only and is not intended to provide reimbursement or legal advice. Laws, regulations, and policies concerning reimbursement are complex and are updated frequently. While we have made an effort to be current, the information may not be as current or comprehensive when you view it. Please consult with your counsel or reimbursement specialist for any reimbursement or billing questions.