Medicare & Medicaid
Eligibility
Specialties
FQHCs
Q: What is ARRA or “the stimulus” and what does it mean for medical practices?
A: The HITECH provisions of the American Recovery and Reinvestment Act of 2009 (ARRA), also known as the “economic stimulus plan”, provide significant financial incentives to assist physicians in the purchase, implementation and meaningful use of a certified electronic health records (EHR) system.
Q: Who is eligible to receive stimulus dollars under ARRA/HITECH?
A: The ARRA outlines two separate EHR incentive programs— a Medicare program and a Medicaid program. Each has its own set of eligibility requirements under the proposed rules.
Under the Medicare program, EHR incentive payments will be available for Eligible Professionals (EPs) that are paid under the physician fee schedule (“PFS”). For Medicare purposes, EPs are those professionals who qualify as “physicians” under the Medicare statute, including doctors of medicine and osteopathy and, for certain limited purposes, dentists, podiatrists, optometrists, and chiropractors. A qualifying EP must demonstrate meaningful use of an EHR as defined by CMS during the specified reporting period
Under the Medicaid program, 'Eligible Professionals" (EPs) include “physicians (defined as M.D.s and Osteopaths and in some limited cases Optometrists), dentists, certified nurse-midwives, nurse practitioners, and physician assistants who are practicing in Federally Qualified Health Centers (FQHCs) or Rural Health Clinics (RHCs) led by a physician assistant.” A qualifying EP must demonstrate meaningful use through a means determined by the State and meet Medicaid volume percentages—20% for pediatricians, 30% for others.
EPs may not receive incentives from both Medicare and Medicaid. EPs must choose to participate in either the Medicare or Medicaid program. They will have one opportunity through the course of the stimulus funding to switch to the other program.
"Hospital-Based" Eligible Professionals - In general, Hospital-Based EPs are not eligible to participate in the EHR incentive programs. A Hospital-Based EP is defined as an EP who “furnishes substantially all of his or her [covered services] in a hospital setting and through the use of the facilities and equipment, including the qualified [EHR], of the hospital." An EP will be considered to be a hospital-based EP if more than 90 percent of the EP’s services covered under the relevant program (that is, Medicare or Medicaid) are billed using the following two place of service (“POS”) codes for HIPAA standard transactions: 21 - Inpatient Hospital and 23 - Emergency Room.
Q: So, what is meant by “meaningful use” and is there a definition?
A: Meaningful use is a central concept under ARRA/HITECH. Purchasing EHR does not, on its own, qualify you to receive stimulus dollars. A provider must actually make “meaningful use” of this technology, as defined by CMS. HITECH specified three requirements for meaningful use: 1) using Certified EHR Technology in a meaningful manner (which includes e-prescribing for EPs); 2) connecting Certified EHR Technology in a manner that provides for the electronic exchange of health information to improve the quality of care; and 3) using the technology to submit to CMS information on clinical quality measures and other measures selected by CMS. In the Final Rule on the EHR Incentives Programs that was released in July 2010, CMS defines a series of criteria that EPs must meet in order to demonstrate that they are "meaningful users" in order to qualify for the incentive payments.
Q: What is meant by “certified” and is Vitera Healthcare Solutions certified?
A: Vitera has maintained (and continues to maintain) current certification with the Certification Committee for Health Information Technology (CCHIT) since its inception in 2006. Alongside the CMS announcement, the ONC announced an initial set of standards, implementation specifications, and certification criteria for EHR systems. Vitera Intergy Meaningful Use Edition V7.0 has been certified as a meaningful use solution for physicians seeking incentives under the HITECH stimulus package released as part of the American Recovery and Reinvestment (ARRA) Act of 2009.
Q: As a physician, how will I receive payment from the federal government and how will they calculate my payment?
A: Providers will receive incentives in the form of additional reimbursement from Medicare or Medicaid.
Under the Medicare program, payments will be calculated by multiplying the allowable charges by 75% and paying reimbursement bonuses up to the capped amount for the year. So, in order to earn the maximum incentive in 2011 ($18,000), you will need to submit claims with allowable charges of $24,000 or more. Qualified eligible providers who do not meet this threshold will receive an amount less than the $18,000 maximum, in proportion to submitted allowable charges.
Under the Medicaid program, an EP may receive “up to 85 percent of the net average allowable costs for certified EHR technology, including support and training (determined on the basis of studies that the Secretary will undertake)” and will receive up to $25,000 in the first year, and up to an additional $10,000 in subsequent reporting years up to the maximum.
Q: Does ARRA require my practice to adopt EHR and participate in the CMS program? Aside from missing out on the incentives, are there any penalties specified if I choose not participate or to adopt EHR?
A: While neither ARRA nor the latest announcement from CMS “require” adoption of EHR, providers who fail to demonstrate meaningful use in the 2014 timeframe face reduction of Medicare payments by 1% a year starting in 2015 and continuing through 2017, with the option to lower fees to 95% of the regular fee schedule. So, in order to gain a full picture of the impact of this decision, medical practices will need to assess the total cost of these penalties over time in addition to the loss of the incentives. There are no penalties associated with the Medicaid program.
Q: My practice does not see Medicare or Medicaid patients. What are the incentives for my practice to adopt EHR and demonstrate meaningful use?
A. There are no specific provisions under ARRA to incentivize providers other than through Medicare/Medicaid reimbursement. However, the door is open for HHS to offer additional incentives after 2011 based on adoption levels. Also, industry experts predict that private insurers will follow suit and begin to offer incentives and/or penalties based on certain meaningful use criteria, including reporting of quality measures.
Q: Will Vitera guarantee that our practice will receive stimulus dollars by using Sage products?
A: We guarantee that the Vitera Intergy Meaningful Use Edition will meet the certification criteria for Meaningful Use set by the Office of the National Coordinator for Health Information (“ONC”). We will modify that offering as necessary to maintain compliance. If we do not, we will credit you up to 12 months of software support.*
Q. How do we begin the process or apply for the funds?
A. Medicare Program - Providers will need to register. Medicare registration will be online at http://cms.gov/EHrIncentivePrograms/. Each state will have their own Medicaid registration process. More details will be released over the coming months.
Medicare funds will be paid on a rolling basis based on an "attestation process". For an EP’s first payment year only, the EP only needs to demonstrate Meaningful Use for a continuous 90-day period and attest that they have met 20 required (15 “core” measures and 5 selected from a “menu” of options) – and are using a qualified system. This “attestation” will happen through a secure web portal. More information on the web portal will be released in the coming months.
More details on Medicare payment:
- Payments will be made through a single payment contractor (rather than EP’s carrier or MAC).
- A new “Integrated Data Repository” (IDR) accumulate EP allowed charges.
- Payments will be made on a rolling basis dictated by 2 milestones:
- CMS ascertains that an EP successfully demonstrated MU for the applicable Reporting Period.
- EP’s allowed charges have reached the qualifying threshold for maximum incentive payment for that Payment Year.
- For EPs who do not reach maximum thresholds, the payment contractor will disburse an incentive payment the following year.
- CMS estimates 15 - 46 days from successful MU attestation to making incentive payments.
- For FY 2011, incentive payments will be made as early as May 2011 (for EPs successfully demonstrating MU for a 90-day EHR Reporting Period).
- EPs will receive a single consolidated incentive payment for a Payment Year (not periodic installments).
Medicare funds will be paid through your carrier or your Medicare Administrative Contractor (MAC) on a rolling basis based on an "attestation process". CMS has proposed to require, for the first year of the bonus program, a 90-day period for which “eligible providers” to attest that they have complied with the 25 measures of “meaningful use” – and are using a qualified system. This written “attestation” will likely be forms you will need to complete to prove that you have a qualified system, and are complying with the 25 criteria for meaningful use. At this time, there is no further detail about the attestation process. States will administer their own Medicaid payments but will follow a similar process.
Q. When is the distribution of the money going to happen?
A. CMS proposes that it will be distributed on a "rolling basis" after the attestation is received. There is no defined time period you'll need to wait between submitting your attestation and actually receiving the check.
Q. We are a group practice of 8 providers and we bill under the same tax ID. Are we eligible for one meaningful use payment or one payment for each provider?
A. The payments are made per eligible professional, not per practice.
Q. Have the stage 2 requirements for meaningful use been outlined? Also, if you sign up can you opt out after the first year or do you have to complete the whole program?
A. No, details regarding "stage two" have not yet been provided. This is an annual program, and you can start -- or leave -- at any time.
Q. What is the difference between CCHIT certification and "meaningful use" certification?
A. CCHIT certifies a comprehensive suite of EHR functionality. Vitera Intergy EHR V7.0 is CCHIT certified for 2011. Meaningful Use certification is a small subset of the CCHIT certification. Vitera Intergy Meaningful Use Edition V7.0 has been certified as a meaningful use solution for physicians seeking incentives under the HITECH stimulus package released as part of the American Recovery and Reinvestment (ARRA) Act of 2009.
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This Complete EHR is 2011/2012 compliant and has been certified by an ONC-ATCB in accordance with the applicable certification criteria adopted by the Secretary of Health and Human Services. This certification does not represent an endorsement by the U.S. Department of Health and Human Services or guarantee the receipt of incentive payments.
* Sage Intergy Meaningful Use Edition v7, Certification date: 7/28/2011, certification ID number: 07282011‐4815‐8, Clinical Quality Measures tested: NQF0001, NQF0002, NQF0004, NQF0012, NQF0013, NQF0014, NQF0018, NQF0024, NQF0027, NQF0028, NQF0031, NQF0032, NQF0033, NQF0034, NQF0036, NQF0038, NQF0041, NQF0043, NQF0047, NQF0052, NQF0055, NQF0056, NQF0059, NQF0061, NQF0062, NQF0064, NQF0067, NQF0068, NQF0070, NQF0073, NQF0074, NQF0075, NQF0081, NQF0083, NQF0084, NQF0086, NQF0088, NQF0089, NQF0105, NQF0385, NQF0387, NQF0389, NQF0421, NQF0575 Additional software used: Email; Compression; Windows OS
*The EHR Product Suite includes Sage Intergy EHR, Sage Intergy Practice Analytics Quality Measures Edition and Sage Intergy Practice Portal.
*To receive EHR Product Suite updates and the credit, you must have an active support agreement and be current on your support payments.
The information in this FAQ was produced and provided by Manatt Health Solutions.
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