Jim Tate, Meaningful Use Expert

Cart Before the Horse? Register after achieving Meaningful use?

We all know (hopefully) that the ABCs of the CMS EHR Incentive Program are: Registration – Meaningful Use of Certified EHR Technology – Attestation. After attestation you hope to get a check so you can go buy your second iPad and a few other toys. Maybe take a trip to an all-inclusive resort in Cancun. But does it have to be that way? Does an EP have to register to begin the process?

The answer, surprisingly, is no. The Medicaid program is a bit quirky in that for the initial  year an EP doesn’t have to actually be using an EHR, meaningfully or otherwise. On the Medicare side those Washington meanies make you do something to get the incentives in your initial year. However, you can get that handy dandy certified EHR, use it enough for the 90 days, and only then perform the required registration. You can even register and attest on the same day. CMS would you prefer you don’t do it all at the last minute (“We encourage providers to register for the Medicare and/or Medicaid EHR Incentive Program(s) as soon as possible to avoid payment delays. Please note that not all states have launched a Medicaid EHR Incentive Program yet, and you should check your state’s status.”) but you can wait till February 29, 2012 if you want to.

February 29, 2012 is the last day for EPs to register and attest to receive an incentive for 2011. Of course you are taking the chance that the Occupy Wall Street folks haven’t taken down the internet by then.

Jim Tate is a nationally recognized expert on the CMS EHR Incentive Program, certified technology and meaningful use and author of The Incentive Roadmap® The Meaningful Use of Certified Technology: Stage 1.