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CMS "Meaningful Use" payment process for 2011

In 2011, each provider is eligible to receive their first $18,000.00 payment from Medicare upon achieving meaningful use of electronic health records. (Medicaid track is different, contact us for details)

There have been may client questions regarding the mechanics of Meaningful Use, payments to providers and timelines. I have read quite a few separate documents regarding the various parts of the registration process but I have not seen one concise document. To clear things up, I have outlined the steps below:

Step 1 - PECOS Registration: Register or update your provider information through the CMS PECOS website. PECOS is the CMS Provider Enrollment, Chain and Ownership System. It manages, tracks and validates your enrollment in the Medicare program. If your enrollment is not up to date, the subsequent steps will fail. https://pecos.cms.hhs.gov/pecos/login.do

FYI: If you are in a group practice, ensure each provider is setup to sign over their incentive payment to the group, otherwise, the incentive checks will go to the providers.

Step 2 - NPPES Registration: Most providers need to have an active user account in NPPES. NPPES is the National Plan and Provider Enumeration System which assigns unique identifiers to providers to allow them to exchange health information. You know it as an NPI or National Provider Identifier https://nppes.cms.hhs.gov/NPPES/StaticForward.do?forward=static.npistart

Step 3 - CMS Meaningful Use Registration: The Centers for Medicare and Medicaid Services (CMS) website for registration, attestation and payment to healthcare providers participating in the "Meaningful Use" program is now live as of January 3rd, 2011. Register at their website to participate in the incentive program. https://ehrincentives.cms.gov/hitech/login.action

There is no penalty for signing up but obviously if you don't sign up, you won't be eligible to receive any incentive dollars later on. Over the coming months, as reimbursement methods change, you will be glad that you did.

Step by step registration instructions:
Log in to the EHRIncentives website using each individual providers user name and password. (Your NPPES login.) In a six doctor practice, you will register six times, each time using a different providers user name and password.

After login, click the [Status] tab and then click on [Select] to the left of the doctors name.

Pick either Medicare or Medicaid for the program type. Choose Medicare unless 30% of the providers patient visits are Medicaid, or in the case of a pediatritian if 20% of the patient visits are Medicaid.

In a group practice, make sure that you pick EIN # instead of SSN for the tax ID option. You will have a drop down listing the name of your group practice. Select the group practice name. On the next line, enter the group practice NPI number. If the group practice is missing from the drop down, you need to go back and check Step 1 and Step 2 as something is setup incorrectly.

Group practices will then have their Meaningful Use checks paid to the practice instead of to each individual provider. An individual provider will have the check made out in their name. Note that the qualification requirement is per provider, the group does not qualify en-mass. The linking here is so that the pay to info is the group.

Once the process is complete, print the completed form showing successful registration. Step 4 & 5 will be completed at the end of 90 days.

Step 4 - Demonstrate Meaningful Use: To qualify, each provider must individually verify that they have demonstrated meaningful use of a certified electronic health records system (EHRs) for 90 days. This is only valid for 2011; in 2012 and beyond, you are required to demonstrate Meaningful Use for the full calendar year.

To accomplish this task, CL Medical will setup a meaningful use dashboard in your practice that will monitor the 35 required measurements for each provider to monitor progress towards achieving 100% compliance. Since this is an all or nothing payment, it is important that each provider knows where they stand.

Step 5 - Attestation or Proof: Upon achieving meaningful use, the provider will log onto the CMS website where they will use the attestation module to describe how they met the requirements by answering a series of questions including questions regarding clinical quality measures.

The concept is the same as submitting a claim for payment. Each time you submit a claim, you are attesting that you rendered those services. Here you will be attesting how you achieved meaningful use.

When it comes time to enter in the attestation data, we'll be here to assist your practice with this process.

Some important points:

1) The payment is per provider, in a group practice each physician attests separately. It is not the "practice" achieving meaningful use but each individual provider. So it is not an all or nothing proposition for the practice.

2) You will answer a series of questions and at the end of the process, the system will tell you if you have achieved meaningful use. It is important to answer the questions accurately.

3) Information from our meaningful use dashboard will be used to answer the questions. You will know ahead of time that you have achieved meaningful use before you answer the questions online at the CMS website.

4) The earliest you will be able to submit attestation is April 1st, 2011. To meet this goal, you need to be currently up and running with an EHR with users at 100% compliance by December 31st, 2010.

5) In subsequent years, qualification for additional payments will be based on submission of detailed data. You are only able to use the attestation method in 2011.

Step 6 - Payment: Incentive checks will be paid starting in May of 2011 for providers who achieve Meaningful Use in Jan - March of 2011 and make their attestation at the beginning of April.

Payment calculation, Medicare will pay each provider 75% of allowed charges up to a maximum of $18,000.00 in 2011. Each provider will need to have $24,000.00 in Medicare allowed charges for 2011 in order to receive the maximum payment. A single check will be cut once the provider reaches their maximum or once the year is over, which ever comes first.

What if your not ready today?

It is important to remember that it will take around four months to get a practice up and running and ready to meet the meaningful use requirements. Once this has happened, you can work towards achieving meaningful use for 90 days if it is prior to October 1st of 2011 at the latest. Otherwise, you'll have to wait for your first payment in 2013 by achieving meaningful use from January - December of 2012.

Don't plan on achieving meaningful use during October - December of 2011. This does not leave any margin of error in case you need to make adjustments. Remember, this is an all or nothing payment per provider based upon achieving 100% compliance. You'll want to keep a couple of month in reserve in case you don't make it at first.

So if you start in January, the earliest you will be able to qualify would be at the beginning of August.

Implementation Timeline?

The latest that you can safely start EHR implementation would be April 1st of 2011 with contracts and planning starting sometime in February of 2011. This will give you April - July to get up to speed, August - October to achieve meaningful use and November and December as a cushion in case you don't achieve 100% compliance in August or September.

However, if you don't want to stick to a strict, everything has to be 100% done within four months, you could start earlier and use the extra time to implement at a pace that better suits your practice.

Of course, if everyone starts at the same time, we won't be able to get to everyone. So if you plan on achieving meaningful use in 2011, please start the process with us sooner, rather than later. To help things along, see incentives below:

Incentives

Clients who start this process in the 1st quarter of 2011 will receive some special incentives from us. This will allow us to smooth out our implementation schedule, providing a better user experience while saving you some dollars at the same time. Contact us for further information.

Alfred Harding--

CL Medical Consulting
4903 82nd Street, Ste 40
Lubbock, TX 79424
(806) 224-0150

 
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