CMS Call: Hospitals weigh in
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As of March 31, the CMS had paid out more than $64 million in Medicaid EHR incentives, and 14 states had activated their Medicaid incentive plans, said Diane Maupai of CMS’ Provider Communications Group, during the call. In addition, there are more than 35,000 active registrations among eligible professionals and eligible hospitals for both the Medicare and Medicaid EHR incentive programs, she said.
Most hospitals are eligible for both the Medicare and Medicaid incentive programs, said Robert Anthony, of CMS’ Office of eHealth Standards and Services. However, it’s important that dually eligible hospitals go through the registration process in the correct way, said Anthony. Failure to indicate correctly what type of hospital you are could cause problems during attestation and payment.
“If you’re a dually eligible hospital, you would select both Medicare and Medicaid as your hospital type at the start of registration in order to keep that program option,” he advised. Although not all states’ Medicaid sites are open for registration, “you’ll still be able to indicate whether you are [eligible for] both Medicare and Medicaid, even if your state isn’t open at this time.” Failure to properly register can cause issues with payment, and eligible hospitals can’t easily change their status later on, he said.
To receive a payment under the Medicare EHR program, hospitals have to attest to meaningful use of certified EHR technology and attest to meeting all objectives and program requirements. Under the Medicaid program, however, hospitals need only adopt, implement or upgrade to a certified EHR system in their first participation year. “If you’re dually eligible, you can potentially [adopt, implement or upgrade-AIU] through Medicaid, [but] you’re still going to have to attest on the Medicare side” in order to receive payment, Anthony said.
Following are some paraphrased questions and answers from the call.
Q: We're in the process of implmenting an EMR, and we’re trying to decide whether completing registration is a good move right now. We implemented part of the EMR for CPOE March 30, so the 90-day attestation period wouldn’t be up until May. Would it be appropriate for us to register now or do we need to wait until we have everything in place?
A: You don’t need to wait to register. In fact, we would encourage you to register now so you can make sure there aren’t operational issues that might delay registration or attestation. There’s no penalty for registering and then never meeting meaningful use.
Q: Regarding attesting for Medicaid—to verify, you can receive incentives from Medicaid without attesting with Medicare?
A: Hospitals that are dually eligible can register for both. Some hospitals have adopted, implemented or udpated, and are eligible for the Medicaid incentive, but aren't sure that they’re going to meet meaningful use this year. That’s fine. If you don’t meet meaningful use this year, there is no penalty to register as dually eligible. As long as your state has launched its program, the state will get you a payment quickly. If your state has not launched its program, your file will be held until the state does launch its program.
Q: To clarify, if we dual register and want to attest for Medicaid in 2011, but we’re not ready to attest to Medicare, there won’t be any issue?
A: That’s right. Also, if you’re not going to meet Medicare meaningful use requirements until 2013, you would skip next year’s payment for the state as well. While you can adopt/implement/upgrade for Medicaid in the first year, you have to start meeting meaningful use after that.
Q: We think we’re a dually eligible hospital, but we don’t have our numbers in yet from the state yet as to whether we meet that 10 percent patient threshold. So is there any danger in registering as dually eligible, if we then find out we actually aren’t eligible on the Medicaid side?
A: It’s fine to do that. Most hospitals should be able to meet the Medicaid patient volume requirement, but there will be a handful that don’t.