Enrolling in the Meaningful Use Program, Part 2

Several months ago, we were considering our eligibility to participate in the federal government’s electronic health record (EHR) incentive program that pays cash incentives to eligible healthcare professionals who make “meaningful use” of certified EHR systems. I mentioned some of our considerations at that time. Now it’s time to look a little closer at some of the details in enrolling.

Meeting the criteria for meaningful use can result in incentive payments of up to $44,000 through Medicare or up to $63,750 through Medicaid. But it takes some work. Each radiologist has to register, attest and own or work with a certified EHR system. Even then, there are a few tricks, most importantly understanding the exemptions to meaningful use criteria that do not apply to radiology.

The way it was pitched, to healthcare with an ambulatory, office-based nature, caused some radiologists to think they could not qualify for the incentive funds. A closer look at the program’s details revealed that many radiologists would have a good shot at earning the incentives.

The penalties for not participating - reductions in Medicare reimbursement - kick in starting in 2015 and will apply all who fail - or choose not - to achieve meaningful use of EHR technology, including radiologists who don’t join in. The only exceptions to the penalties are those considered hospital-based physicians.

Again, with that news, many radiologists stopped reading. But, CMS defines hospital based as billing more than 90 percent of Medicare services annually with the place-of-service codes for hospital or ER setting. So there are a few radiologists who are exempt. But many of us, even those who primarily are hospital-affiliated, are not exempt. So before you relax, look a little harder.

Lastly, some practices and physicians believe the rules only are for government-pay patients. But the meaningful use measures apply to all patients, not just those covered by Medicare or Medicaid.

So, what is the process?

Exemptions

Radiologists will be exempt from a number of the measures. The government allows exemptions from 13 of the 25 meaningful use criteria in 2011 and 2012. Exemptions can be triggered by not performing a sufficient number of actions or having a sufficient number of patients in the measured category. For example, a radiologist who writes fewer than 100 prescriptions during the annual EHR reporting period would be excluded from the criteria to electronically generate and transmit more than 40 percent of permissible prescriptions annually.

Likewise, the criterion to provide clinical summaries for more than 50 percent of all office visits within three businesses to patients who request them does not apply to eligible professionals who have no office visits.

Best of all, an eligible professional who is exempt from a criterion is not required in most cases to substitute another one.

So have your administrator pull all the criteria and take a look at from what you are exempt.

Registration and attestation

Everyone has to register, individually, for the program. Registering for the program requires your National Provider Identifier (NPI), and will require you to use your practice’s tax ID number and group NPI as well, which you should be able to get from your practice administrator. Lastly, you’ll need to be enrolled in the government’s Provider Enrollment, Chain and Ownership System (PECOS), so verify that with your business office.

Registration has been open since earlier this year. Once registered, you’ll need to ultimately attest to successfully achieving meaningful use on a certified system. Remember, don’t attest until you can document that you are in compliance. It is not enough to believe you are compliant. Attesting without documentation, even if you are compliant, is the same as fraud to CMS.

Payment

Attestation (the government’s term for reporting meaningful use) for the Medicare incentives is made to CMS. For the Medicaid program, it is made to a state Medicaid EHR program. Bonuses through the Medicare program during 2011 are available after attesting to 90 days of successful participation.

Medicare physicians who successfully attest to meaningful use will receive the incentive funds in a lump sum about four to six weeks after attesting to meaningful use of certified EHR technology, although the specific timing is not yet known. The funds will be sent through the claims payments system to your group.

While the EHR incentive program is not mandatory, the penalties for not participating are. Right now you may be leaving money on the table. Radiologists who decide not to participate in future years will be penalized with a lower Medicare reimbursement starting in 2015.