Medicare or Medicaid EHR incentives? 6 things to consider
Now more than ever, providers are exploring whether the Medicare or Medicaid reimbursement program is best to receive their EHR incentive payments. For many, both are an option, and according to Stephen Martinez, CEO at MTS Healthcare, it's imperative to understand the ins-and-outs of each in order to make an educated decision.
"We are often asked by providers whether they should apply for their EHR incentives through Medicare or Medicaid," he said. "While many providers are aware the financial incentives are for different amounts, the reporting and eligibility requirements are also very different. "
Martinez outlines six keys to EHR incentives and Medicare versus Medicaid.
Medicaid:
1. Providers can apply for their first payment under "A/I/U." To receive the entire $63,750 from the Medicaid incentive program, said Martinez, providers can apply for their first payment under what's called A/I/U. "That is, they can either adopt – acquire or secure access to – an EHR system, implement or begin using, an EHR system, or upgrade their EHR system that's already in use," he said. "[Then] they're eligible to receive the first year payment of $21,250."
2. Providers who apply under the Medicaid program don't need to attest to MU during their first payment year. "They simply need to attest to A/I/U," said Martinez. In providers' second payment year, or the first year of demonstrating MU, providers have a 90-day meaningful use reporting period requirement, he continued. "Only beginning in their third payment year, or the second year of demonstrating MU, will providers have to attest for the full 12-month period, and for every year beyond in order to receive their payments," he said.
[See also: Medicare EHR incentive payments expected this week.]
3. Provider eligibility is based on the percentage of Medicaid patient volume seen at the practice. If 30 percent of the patient volume is fee-for-service, or managed care Medicaid, Martinez said, providers can qualify for the Medicaid EHR incentive program. "Pediatricians can qualify with a lower minimum of 20 percent Medicaid patient volume and will be paid 66 percent of the Medicaid incentive. But [they could] be paid the full amount if their patient volume is 30 percent or greater."
Medicare:
1. Providers need to demonstrate 90 consecutive days of MU. To receive the entire $44,000 under the Medicare reimbursement program, said Martinez, providers need to demonstrate 90 consecutive days of MU beginning in 2011 or 2012. "Providers who were ready could have begun their 90-day reporting period for MU on January 1, 2011," he said. "If they had successfully passed the MU measures for 90 days, they could have applied on April 1, 2011 for their first financial incentive payment of $18,000."
pjcasey75 say: Skip years or change programs?
Speaking strictly as a financial analyst: two other important things to consider: If you opt for the Medicaid route, you are allowed to skip a year or multiple years, resuming your incentive claims when you resume your compliance with the meaningful use requirements applicable in that year. Practically speaking, that means you could apply for the heavily front-ended AIU payment in 2012 and then wait as late as 2016 to start meeting meaningful use (which will, admittedly, be much tougher to meet by then), and still receive your max payments under the Medicaid program as it runs through 2021 (barring the Congressional axe which might fall on the program by then).
Why wait? Well, IT technology usually matures pretty rapidly which means it gets cheaper and typically easier to use over time. You may want to let others be the guinea pigs. The other advantage to the ability to skip years is that you may anticipate an interruption in your practice (switch EHRs, switch practices, leave the country for a spell?) or in the continuity of your EHR implementation some time during the next 5 to 8 years. Under some scenarios, it may prove a little more difficult to maintain compliance under Medicare. Under Medicaid, not so much. Personally, I like options. And if for some reason something goes horribly awry (I miss a reporting deadline, my volume slips below 30%, someone inadvertently turns off a key decision support function) - such that I can't meet MU for a given year, I haven't lost the chance to still get more incentive checks for say, 4 more years, just because something went wrong early on.
Second, you are allowed to switch your participation in the program from Medicare to Medicaid or vice versa one time during your participation in the incentives.
Speaking as a technology consultant: The early adoption stage is pretty much over. EHR products and services now are entering a growth and prime development stage. HIE is still emerging, but will soon be significant. Now is a good time to adopt the technology if you want some voice in directing how the products are designed to meet your needs. You'll also be an experienced user by the time patient volume and e-health services become critical factors in your practice profitability and competitiveness. Otherwise the learning curve that every new implementation encounters, experienced later in the game, may hurt you even more in the face of many more technologically adroit competing practices.