The Electronic Health Records (EHR) Meaningful Use (MU) Incentive Program is an initiative from CMS designed to facilitate the use of EHRs in clinical settings. Eligible professionals (EPs), hospitals, and critical access hospitals that demonstrate MU of EHRs are eligible for incentive payments. For EPs, incentive payments can accumulate up to $44,000 by 2015 if they began to successfully participate in 2012. Starting in 2015, EPs, hospitals and critical access hospitals that do not successfully demonstrate MU of EHRs will be subject to penalties starting with a 1% payment reduction in 2015 (based on 2013 reporting) and increasing annually to 5% by 2020.
The EHR MU Incentive Program is structured in three stages, with a possible fourth stage starting as early as 2018. Below is a snapshot of implementation dates for the EHR Incentive Program through 2016:
1st Payment Year
|2011||Stage 1||Stage 1||Stage 2||Stage 2||Stage 3|
|2012||Stage 1||Stage 1||Stage 2||Stage 2||Stage 3|
|2013||Stage 1||Stage 1||Stage 2||Stage 2|
|2014||Stage 1||Stage 1||Stage 2|
|2015||Stage 1||Stage 1|
In order to obtain the full $44,000 in incentive payments, EPs must have begun participating in the EHR MU Incentive Program by October 3rd, 2012. Starting in 2013, incentive payments will be reduced annually and EPs will be subject to payment penalties, beginning in 2015.
1. Getting Started
CMS has developed a number of resources for you to see if you are eligible to begin participating in the EHR MU Incentive Program, as well as instructions on how to register and tips on how to successfully attest to MU, earn incentive payments, and avoid Medicare Payment Penalties. See the CMS Getting Started page here.
2. How to Earn Incentive Payments and Avoid Penalties
First, you must purchase an Office of the National Coordinator (ONC) Health IT Certified EHR System. The ONC Certified HIT Product List (CHPL) is a comprehensive list of Complete EHRs and EHR Modules that have been tested and certified by an ONC-Authorized Testing and Certification Body (ATCB) under the Temporary Certification Program. CMS will only grant and accept reporting numbers from the EHR technologies on the ONC-Certified Health IT Product List. These reporting numbers are required for attestation under the EHR MU incentives programs. The Certified Health IT Product List should help members find an appropriate CEHRT to meet the needs of their practice.
*IMPORTANT CHANGE FOR 2014* New standards and certification criteria take effect in 2014! Even if an EP already has a certified EHR, he or she will have to adopt or upgrade to the new certification in order to participate in the program. If the EHR is certified to 2014 standards/certification criteria, then providers should be able to meet both Stage 1 and Stage 2 requirements.
**NOTE** CMS updated language in its "hardship exception" applications for Fiscal Year 2015 for both eligible hospitals and eligible professionals participating in the Medicare Meaningful Use incentive program. Those who struggled to adopt or upgrade to 2014 CEHRT, may qualify for a hardship.
**NOTE** In September 2014, CMS released a final rule that allows providers to use the 2011 Edition of Certified Electronic Health Record Technology (CEHRT) for 2014. Providers unable to fully implement 2014 Edition CEHRT for an EHR reporting period in 2014 due to availability delays may now use EHRs that are certified under the 2011 Edition, a combination of 2011 and 2014 Editions, or the 2014 Edition. To determine whether you are eligible, click here.
Next, you must report the required number of MU Objectives (Core Objectives + Menu Objectives) PLUS the required number of Clinical Quality Measures (CQMs) and meet other reporting requirements, such as:
- For your first year, report data from any continuous 90-day period during the calendar year (any 90 continuous days from January 1st to December 31st)
- After your first year, report for the entire calendar year (January 1st to December 31st). Special Note for 2014: All providers, regardless of their stage of MU, are only required to demonstrate MU for a 90-day EHR reporting period because all must upgrade or adopt newly certified EHRs in 2014.
- After two or three program years under Stage 1, providers progress to Stage 2. 2014 is the earliest year to begin Stage 2, and its requirements differ from that of Stage 1.
- For 2014, all participating providers (regardless of which stage they’re in) are required to demonstrate MU for a three-month reporting period. Those beyond their first year of MU must select a 3-month period fixed to a quarter of the calendar year.
- *Note: If none of the menu objectives are applicable to your scope of practice and you qualify for all of the exclusions for each objective, then you can select any 3 and claim the exclusion for each.
- ** The CQMs selected must cover at least 3 of the 6 available National Quality Strategy domains.
- IMPORTANT CHANGE FOR 2014: EHR technology that is certified to the 2014 standards will contain new CQM criteria, and EPs will report using the new 2014 criteria, regardless of whether an EP is participating in Stage 1 or Stage 2. Remember, attestation for the EHR MU Incentive Program is not complete until CQM data is submitted!
3. Need More Information on the Programs?
View the Following Documents Published by CMS on the Medicare EHR MU Incentive Programs:
- Medicare EHR MU Incentive Program Tipsheet
- Specialty Physician Tipsheet
- Participation Timeline – (Helps determine what stage you’re in in the program)
- Overview of Stage 1 Requirements (for 2013)
- Overview of Stage 1 Requirements (for 2014)
- Guide to Stage 2 (Helps guide you through specific measure requirements, selecting CQMs, how to submit data, and much more!)