CMS: Attestation looms, questions remain
With meaningful use attestation a mere two weeks away, a 90-minute National Provider Call on Registration hosted by the Centers for Medicare & Medicaid Services (CMS) on April 1 devoted roughly half an hour to a presentation on registering eligible professionals (EPs), and an hour to answering attendee questions.
As of Feb. 28, more than 25,000 providers had registered in the program, and the Centers for Medicare and Medicaid Services (CMS) has paid out more than $37 million in Medicaid incentives, according to the CMS website.
Eligible professionals may switch between the Medicaid and Medicare incentive programs, but may do so only once after having received an incentive payment; and the switch must occur before 2015. Medicare incentive payments will start in mid-May for EPs who register and successfully attest to meaningful use before April 22. The payment schedule is mid-month for attestations made the previous month going forward.
Following is a sample of the National Provider Call questions and answers.
Q: As we’re trying to determine how to register, whether Medicaid or Medicare, it says in the regulations that we have to take our Medicaid encounters in the numerator versus our total encounters in denominator. Is that E&M [evaluation and management] or is it CPT [Current Procedural Terminology] coding when we do those totals?
A: It depends on what state you’re in. Each state is allowed to operationalize the Medicaid provision in ways that make sense according to the data they have.
Q: I mainly see patients in hospital but I also see patients in a skilled nursing facility. I do qualify as an EP, but my concern is that my office practice is tiny—I’m an infectious disease physician … because patients are in a setting where I’m not able to use an EHR or e-prescribing, I am not able meet program requirements, nor am I able to find an exemption that addresses that issue.
A: There are a number of people in your situation. There is no exception to that rule right now, and we don’t know how penalties are going to be applied. If you’re not able to meet that 50 percent threshold, you would not be able to demonstrate meaningful use at this point. CMS will be publishing additional information in the future.
Q: We are getting ready to move to an e-prescribing solution soon, and to an EMR by the end of the year. I know there are incentive programs for e-prescribing and for EHRs, and I know they overlap and the merge at some point, but I don’t have a clear understanding of how they all work together, and what we’re eligible to apply for as we start this process.
A: Essentially, there are three different reporting programs, all of which have different requirements and eligibilities. You can participate in this program and in PQRS. For e-prescribing and an EHR incentive program, if you are participating in Medicare EHR incentive program, you are required to report for e-prescribing, but you can only receive one incentive payment, and the incentive payment that you will receive will be the EHR program incentive payment.
If you are a Medicaid EP, you can enroll in both and actually receive both of those payments.
Q: We are looking at upgrading to a version of our software that will be compliant with meaningful use requirement in late 2011. For the time being, our practice is reporting under e-prescribing. If we register prior to the end of 2011, are we going to negate the e-prescribing incentive that we might have earned throughout 2011? I’d hate to lose a year’s worth of e-prescribing incentive that we’ve earned, if we need to time our registration for meaningful use so that doesn’t occur, since we won’t be eligible for meaningful use until closer to 2012.
A: It is certainly possible for folks to forgo meaningful use of the EHR incentive program in 2011 and opt to receive the e-prescribing incentive during that year, and push their meaningful use demonstration to 2012. It’s an option that you’re going to have to consider whether it makes sense for your practice or not or for you as an EP. But if you do attest in 2011, and successfully demonstrate meaningful use, you are only going to receive that EHR incentive program payment.
You could register in 2011 and not necessarily attest in 2011. It’s attestation in the program that does that; registering for it is not going to negate the receipt of the payment.
As of Feb. 28, more than 25,000 providers had registered in the program, and the Centers for Medicare and Medicaid Services (CMS) has paid out more than $37 million in Medicaid incentives, according to the CMS website.
Eligible professionals may switch between the Medicaid and Medicare incentive programs, but may do so only once after having received an incentive payment; and the switch must occur before 2015. Medicare incentive payments will start in mid-May for EPs who register and successfully attest to meaningful use before April 22. The payment schedule is mid-month for attestations made the previous month going forward.
Following is a sample of the National Provider Call questions and answers.
Q: As we’re trying to determine how to register, whether Medicaid or Medicare, it says in the regulations that we have to take our Medicaid encounters in the numerator versus our total encounters in denominator. Is that E&M [evaluation and management] or is it CPT [Current Procedural Terminology] coding when we do those totals?
A: It depends on what state you’re in. Each state is allowed to operationalize the Medicaid provision in ways that make sense according to the data they have.
Q: I mainly see patients in hospital but I also see patients in a skilled nursing facility. I do qualify as an EP, but my concern is that my office practice is tiny—I’m an infectious disease physician … because patients are in a setting where I’m not able to use an EHR or e-prescribing, I am not able meet program requirements, nor am I able to find an exemption that addresses that issue.
A: There are a number of people in your situation. There is no exception to that rule right now, and we don’t know how penalties are going to be applied. If you’re not able to meet that 50 percent threshold, you would not be able to demonstrate meaningful use at this point. CMS will be publishing additional information in the future.
Q: We are getting ready to move to an e-prescribing solution soon, and to an EMR by the end of the year. I know there are incentive programs for e-prescribing and for EHRs, and I know they overlap and the merge at some point, but I don’t have a clear understanding of how they all work together, and what we’re eligible to apply for as we start this process.
A: Essentially, there are three different reporting programs, all of which have different requirements and eligibilities. You can participate in this program and in PQRS. For e-prescribing and an EHR incentive program, if you are participating in Medicare EHR incentive program, you are required to report for e-prescribing, but you can only receive one incentive payment, and the incentive payment that you will receive will be the EHR program incentive payment.
If you are a Medicaid EP, you can enroll in both and actually receive both of those payments.
Q: We are looking at upgrading to a version of our software that will be compliant with meaningful use requirement in late 2011. For the time being, our practice is reporting under e-prescribing. If we register prior to the end of 2011, are we going to negate the e-prescribing incentive that we might have earned throughout 2011? I’d hate to lose a year’s worth of e-prescribing incentive that we’ve earned, if we need to time our registration for meaningful use so that doesn’t occur, since we won’t be eligible for meaningful use until closer to 2012.
A: It is certainly possible for folks to forgo meaningful use of the EHR incentive program in 2011 and opt to receive the e-prescribing incentive during that year, and push their meaningful use demonstration to 2012. It’s an option that you’re going to have to consider whether it makes sense for your practice or not or for you as an EP. But if you do attest in 2011, and successfully demonstrate meaningful use, you are only going to receive that EHR incentive program payment.
You could register in 2011 and not necessarily attest in 2011. It’s attestation in the program that does that; registering for it is not going to negate the receipt of the payment.