Facts To Consider When Enrolling In A CMS EHR Incentive Program

Posted on by Frank J. Rosello

More than ever before, eligible providers are exploring which EHR incentive program is best to enroll in to receive their EHR incentive payments. The choices are either the Medicare or Medicaid EHR incentive program. For many eligible providers, both are an option, and it’s imperative for them to understand the ins-and-outs of each incentive program in order to make the best informed decision.

Our clients and prospects are constantly asking which EHR incentive program should they should apply for their EHR incentives. While many providers and medical organizations are aware the financial incentives are for different amounts, it is very important to note that the reporting and eligibility requirements are also very different.

Here are six key facts eligible providers should consider when evaluating the Medicare and Medicaid EHR incentive programs:


1. Providers can apply for their first payment under “A/I/U.” In order for eligible providers to receive the entire $63,750 incentive from the Medicaid incentive program, providers can apply for their first payment under what’s called A/I/U.  This means that the provider 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. By taking this action, eligible providers become 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. All eligible providers simply need to attest to A/I/U.  In providers’ second payment year, or the first year of demonstrating MU, providers have a 90-day meaningful use reporting period requirement. 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 be eligible to receive their future payments.

3. Provider eligibility is based on the percentage of Medicaid patient volume seen at the practice.
If thirty percent of the patient volume is fee-for-service, or managed care, eligible providers can qualify for the Medicaid EHR incentive program. Specifically, pediatricians can qualify with a lower minimum of twenty percent Medicaid patient volume and will be paid sixty-six percent of the Medicaid incentive. However, eligible providers may qualify to be paid the full amount if their Medicaid patient volume is thrity percent or greater.


1. Providers need to demonstrate 90 consecutive days of MU.  In order for eligible providers to receive the maximum $44,000in incentive payments under the Medicare EHR incentive program, providers need to demonstrate ninety consecutive days of MU beginning in 2011 or 2012. Eligible providers who were ready could have begun their ninety day reporting period for MU on January 1, 2011. If they had successfully attested to meeting the MU measures for 90 days, they could have applied on April 1, 2011 for their first financial incentive payment of $18,000. October 3, 2012 is the last day for eligible professionals to begin their ninety day reporting period to demonstrate meaningful use for the Medicare EHR Incentive. As of today, there are only seventy days remaining for first year eligible providers to begin their ninety day meaningful use reporting period.

2. Providers also need to demonstrate MU for all of 2012 and for each subsequent year. Providers that demonstrated ninety days of MU in 2011 must also demonstrate MU for the full 12- month period of 2012 and for each subsequent year in order to receive the maximum payments. It is important for eligible providers to remember the ninety day reporting period must begin before October 3, 2012 to receive the financial incentive for that payment year. After October 3rd, the ninety day reporting period would cross over into the following calendar year. While eligible providers would still receive $18,000 if they attest for MU in 2012, they would have to wait until 2013 to receive their second payment of $12,000.

3. Under Fee-For-Service, the payment incentive amount is subject to an annual limit. Under fee-for-service Medicare, the payment incentive amount is subject to an annual limit, which is equal to seventy-five percent – up to $18,000 – of a provider’s Medicare allowable charges submitted no later than two months after the end of the calendar year. For either 2011 or 2012, the EHR incentive amount could not exceed $18,000, but it could be less based on charges submitted to Medicare.

Click here to access the CMS Medicare and Medicaid EHR Incentive Programs web site.

Frank J. Rosello

is CEO & Co-Founder of Environmental Intelligence LLC.

Environmental Intelligence, LLC, is a complete, full-service healthcare IT solution provider. With a team having more than 10 years of proven clinical expertise in delivering end-to-end health IT solutions, Environmental Intelligence provides medical practices and facilities onsite expert IT consulting, installation, and implementation that is focused on physicians, their patients, and the quality of their care.

Contact us to learn more about our Physician Focused – Patient Driven® approach to Health IT.

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