September 26, 2011

The CY2011 EHR Incentive Payment Deadline Fast Approaching

Filed under: CMS,EHR Incentive,Meaningful Use — HankMayers @ 10:57 pm

Well, for eligible practitioners (EP) who would like to earn a 2012 EHR Incentive payment, they’d better be meaningfully using their EHR. That’s because starting on October 3, 2011 is the final 90-day window to satisfy the Meaningful Use criteria to earn an incentive payment for 2012 in either the Medicare or Medicaid programs.

If the EP fails to meaningfully use its EHR for all 90 days to 12/31/11, they’ll need to try again. Truth is, if the EP discovers that s/he fails to meet the criteria during part of that window, s/he can start over then – reset the clock. The EP’s 90 window is not limited to any particular window of time. That is, it does not have to neatly fit an annual quarter or whatever. It is 90 days after you set your start day.

So, if a late-starting EP trips during this last quarter of the year, the only loss is the cash flow of the practice. While that can be a serious consideration for the practice, they are not looking at any federal funding loss – just a delay until they get their meaningful use performance nailed down.

By the way, if a Medicare provider waits till 2012 to implement, and waits to start meaningfully using the EHR on 10/1/12 AND then fails to satisfy the Meaningful Use criteria for the entire 90 days to 12/31/12, then his 1st payment will be earned after 2012, and that means he will receive $5,000 less over the 5 year window than if he had met Meaningful Use by 2012. This loss only happens in the Medicare program.

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