Jim Tate, Meaningful Use Expert

Last Date to Meet EHR Incentive Program Requirements

Several times a week I am asked the same question by providers and vendors. The question takes different twists and turns, but it all gets down to one core concern. To put it in the crassest terms, here it is. “What is the absolutely last drop dead date an eligible professional can meet the CMS EHR Incentive Program requirements and not leave any money on the table?” OK, now that the question is clear, let’s answer it once and for all.

For Eligible Professionals there are two CMS programs, Medicare and Medicaid, which incentivize EHR use. An EP must select one of the programs for participation, and is allowed to switch programs once. Let’s take a look at Medicaid first. 2016 is the “Last year to initiate participation in the Medicaid EHR Incentive Program” and 2021 is the “Last year to receive Medicaid EHR Incentive Payment.”

Now, let’s take a look at the CMS matrix on page 4 of this document: From the matrix it is clear that a Medicaid EP whose first year in the program is 2016 has the potential to receive receiving the maximum incentive of $63,750. The same as an EP who entered the program in 2011.

For Medicare EPs it is a little more complicated as the incentives are front end loaded. Looking at page 5 on the CMS matrix located on the CMS website we can see that a Medicare EP can get the maximum incentives by beginning participation in either 2011 or 2012. To ease the path for the first year for Medicare EPs CMS states: “The reporting period for the first year is any 90 continuous days during the calendar year.” It doesn’t matter what year the Medicare EP begins, they only have to hit 90 days their first year. So to get the maximum Medicare incentive the EP must begin 2011 or 2012 with a 90 day period of the demonstration of meaningful use of certified EHR technology.

To bring it all to the bottom line here it is, short and sweet. For Medicaid EP the deadline for maximum incentives is 2016, and they only have to have signed a contract for a certified EHR that first year. For Medicare EPs the deadline is 90 days in 2012 which my calendar shows as October 3rd 2012.

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.