The Centers for Medicare and Medicaid Services (“CMS”) published important payment adjustment information this week for health care providers participating in the Medicare Electronic Health Records Incentive Program (“Incentive Program”).
Eligible Professionals (“EPs”) participating in the Incentive Program may be subject to payment adjustments beginning January 1, 2015. CMS will determine the payment adjustment based on meaningful use data submitted prior to the 2015 calendar year. This means that EPs must demonstrate meaningful use prior to 2015 to avoid payment adjustments. The year an EP starts will affect the 2015 payment adjustments.
- If an EP first demonstrated meaningful use in 2011 or 2012, the EP must demonstrate meaningful use for a full year in 2013 to avoid the payment adjustment in 2015.
- If an EP first demonstrated meaningful use in 2013, the EP must demonstrate meaningful use for a 90-day reporting period in 2013 to avoid the payment adjustment in 2015.
- If an EP first demonstrates meaningful use in 2014, the EP must demonstrate meaningful use for a 90-day reporting period in 2014 to avoid the payment adjustment in 2015. This reporting period must occur in the first nine months of calendar year 2014, and the EP must attest to meaningful use no later than October 1, 2014 to avoid the payment adjustment.
Avoiding Payment Adjustments in the Future
An EP must continue to demonstrate meaningful use every year to avoid payment adjustments in subsequent years.
If an EP is eligible to participate in both the Medicare and Medicaid EHR Incentive Programs, the EP must demonstrate meaningful use to avoid the payment adjustments. The EP may demonstrate meaningful use under either Medicare or Medicaid.
If an EP is only eligible to participate in the Medicaid EHR Incentive Program, the EP is not subject to these payment adjustments.
If you have questions regarding meaningful use and possible payment adjustments, please contact Jeff Short at 317-977-1413 or jshort@wp.hallrender.com, Ammon Fillmore at 317-977-1492 or afillmore@wp.hallrender.com or your regular Hall Render attorney.
