In the free webinar, What Small Practices Need to Know about Meaningful Use Now, Barbara Drury, FHIMSS, discussed the history of Meaningful Use, what you need to know to participate if you start now, and where she thinks we are headed. She covered a lot of ground, and participants had a lot of questions. We’ve selected the top questions to share with everyone.
Q: If we switch EHR’s after we attested for Stage 1, will we be penalized for using a new EHR for the next year or for Stage 2?
A: No, you will not be penalized for changing to a new EHR. If you attested to Stage 1 for the first year (or two) and then changed to a new EHR, what matters is that the new EHR is certified and allows you to attest again (for Stage 1 or 2). It is the reporting of the data that qualifies you for the incentives not the brand of EHR (although to attest your EHR needs to be certified). However, if you attested for MU1 on EHR #1 and the next year you switched to EHR #2, your reporting period to meet the measures is 365 days for MU1, year 2, even though it is the first year you have used EHR #2.
Q: What if a doctor makes less than $10,667 in allowable Medicare charges?
A: It does not matter how much or how little Medicare you bill because the incentive (which is different depending on what year you are in), is a CEILING, not a guarantee. So if the maximum incentive for 2013 is $15,000 but you only billed Medicare $10,000 in the calendar year, you would earn an incentive of 75% of what your allowable was (i.e., allowable for the calendar year was $10,000, then your incentive would be $7,500). On the other hand, if your calendar year allowable billed was $500,000 your incentive would not be 75% of $500,000 ($375,000), it would be $15,000, which is the maximum ceiling.
Q: What if a provider is new and does not start his new practice until 2014?
A: I recommend getting started as soon as possible. I believe they get a two year grace period without the penalty kicking in. For more details I would suggest looking at www.cms.gov because eventually the penalty does take effect.
Q: What happens under the Medicaid incentive if you have a practitioner who leaves your practice?
A: The incentive program for both Medicare and Medicaid is at the individual physician level, so if you have three EPs, and two work all year, each has 4,000 total office visits in the calendar year, then to qualify for Medicaid (not peds Medicaid), each of these EPs would need to have 30% or more Medicaid paid visits in the year – or at least 1,200 MCD visits each to be eligible to earn the Medicaid incentive. The MD that leaves, maybe only had 1300 Medicaid visits during his time in the practice, then if 30% or more of the 1300 were paid by Medicaid, and the measures are met, the state should pay the Medicaid incentive to the tax ID reported in the attestation process.
Q: We are using a couple of EMR’s. I see folks in nursing homes, hospitals, skilled nursing facilities. Where do I qualify for the incentives?
A: There are some guidelines for how you qualify for MU if you are seeing patients in more than location. There must be a certified EHR at the location and you must spend at least 50% of your time at that location and the measures are only looking at patients where the POS billing code is either 11 (office), 20 (urgent care facility), 49 (independent clinic) and 24 (Ambulatory Surgery Center). So you would need to do an analysis of the places where you see patients and determine which location fits the requirements. For more details, visit www.cms.gov.
Q: So is Meaningful Use going to be never ending? We will still have to do it even without incentives? Also, we attested for stage 1 in 2012 and are now in 2013. Do we attest to stage 2 now?
A: Since we can’t see into the future, we don’t know how long Meaningful Use will continue. Right now it is funded through 2016. It may end there, but the concept of being a meaningful user will probably continue. We do expect to see Stage 3 and Stage 4 details coming in 2014. In the meantime, we do know that for the next few years we will continue to have Meaningful Use incentives and, starting in 2015, penalties. If you attested to Stage 1 in 2012 then you would attest to Stage 1 again in 2013 for 365 days. Stage 2 doesn’t begin until 2014.
Q: Can NPs, PAs, PTs, OTs, SLPs, or social workers qualify for Meaningful Use incentives?
A: None of these can qualify for Medicare incentives. The one exception to this is the case of a PA or NP who is the primary provider and/or owner of a rural health clinic. Mid-level providers (NPs and PAs) can qualify for Medicaid incentives. However, to do so requires that the provider have a minimum of 30% of their visits billed to Medicaid. EPs in a pediatric practice must only meet a 20% Medicaid visit threshold to receive 2/3 of the Medicaid incentive that an EP who has 30% or more Medicaid visits earns.
Check out the recorded webinar to get all of the great information provided there. And take a look at our next event, 5 Critical Activities to Prevent a Government Audit.
About the Speaker
Barbara Drury, BA, FHIMSS, is President of Pricare Inc., an independent health information technology consulting firm founded in 1982. She frequently lectures and writes about the impact of office-based computer systems and electronic medical record systems for entities such as medical societies, healthcare organizations, and others. Ms. Drury is an appointee to the ONC’s Technical Expert Panel on Unintended Consequences of HIT Adoption. She has achieved Fellow Status with the Healthcare Information and Management Systems Society (HIMSS) and currently serves on the HIMSS Public Policy Committee. Ms. Drury is also a frequent speaker at the HIMSS Annual Conference and is the recipient of the December 2004 and the April 2009 Spirit of HIMSS award.