The American Recovery and Reinvestment Act (ARRA) is the legislation that became a law last year that established Medicare and Medicaid incentive programs for health care professionals to adopt and use health information technology. The proposed regulation released a few weeks ago is the resulting work of that legislation to define how the incentive program will work.
The goals of meaningful use are to:
- improve quality, safety, efficiency
- reduce health care disparities
- engage patients and their families; improve care coordination
- improve population and public health and ensure adequate privacy and security protections
Medicare and Medicaid professionals, including physicians, are eligible for the health IT incentives. At this time, physicians (non-hospital based) are eligible for Medicare incentive payments based on an amount equal to 75 percent of the allowed Medicare part B charges, up to a maximum of $18,000 for early adopters whose first payment year is 2011 or 2012.
Under the Medicare incentive program, each eligible professional (EP) no matter what size the practice, could qualify for up to $44,000 in Medicare incentives over a five-year period, 2011-2016. Under the Medicaid incentive program, eligible pediatricians (non-hospital based) could receive up to $42,500, and other physicians (non-hospital based) could receive up to $63,750, over a six-year period.
CMS has proposed that the reporting period for eligible professionals under both Medicare and Medicaid incentive programs for the first year would be any continuous 90-day period within a calendar year. For the second, third, fourth, and fifth years, it would be the entire calendar year. The 90-day reporting period could not start before January 1, 2011 or cross over into the next year.
According to the rule, both Medicare and Medicaid eligible professionals would receive a single, consolidated, annual incentive payment. Medicare’s eligible professionals would be paid electronically via their Medicare contractor. Medicaid EPs would receive payment from either the State Medicaid agency or their designated intermediary (i.e., a Medicaid HMO). Tracking will be done at the unique National Provider Identifier (NPI) level. Both Medicare and Medicaid EPs will need to supply their name, NPI number, business address and phone and Taxpayer Identification Number (TIN) to be paid accurately and quickly.
CMS has proposed that hospital-based EPs are not eligible according to the ARRA definition which states, “hospital-based eligible professionals” means, with respect to covered professional services furnished by an eligible professional during the EHR reporting period for a payment year, an EP who furnishes substantially all (90 percent) of such services in a hospital setting (whether inpatient or outpatient) and through the use of the facilities and equipment, including qualified electronic health records, of the hospital.
While audits were not discussed in the proposed regulation, since CMS has oversight of the meaningful use of EHR requirements, it is likely they would oversee any audits associated with the Medicare incentive program. It is also possible that states would engage in this function for Medicaid. However, these details have not yet been determined.
To view the eligible provider and hospital “Meaningful Use” criteria, please visit the CMS website.
The information in this column is for informational purposes only and does not dictate an exclusive course or procedure to be followed.