Incentive Payments - How and When?

We're all interested in the how and when of incentive payments, right? CMS has published an updated and thorough response. If you want the full meal deal, read it here. ECPs with a lesser appetite and attesting through Medicare may want the snack version:

When? 4-8 weeks following successful Attestation. "For eligible professionals (EPs), incentive payments for the Medicare EHR Incentive Program will be made approximately four to eight weeks after an EP successfully attests that they have demonstrated meaningful use of certified EHR technology."  

A "yes, but ..." to help you get the maximum payment. "However, EPs will not receive incentive payments within that timeframe if they have not yet met the threshold for allowed charges for covered professional services furnished by the EP during the year. Payments will be held until the EP meets the $24,000 threshold in allowed charges for the calendar year in order to maximize the amount of the EHR incentive payment they receive. ..." 

So who actually gets paid? "Payments to Medicare EPs will be made to the taxpayer identification number (TIN) selected at the time of registration, through the same channels their claims payments are made. The form of payment (electronic funds transfer or check) will be the same as claims payments."

A Case in Point.
So here's a common scenario. You started your initial MU period in 2011 but, for one reason or another, you were unable to attest successfully. Now you need to start over. Have you lost the 2011 money? When can you expect to receive your money assuming you attest successfully in 2012?


First, no you have not lost the 2011 money. Remember that 2012 is equally acceptable as your Year 1. Though obviously your payment is delayed, you lose nothing. (The same is not true of 2013 or 2014. You will lose money by delaying past Oct.3, 2012.)


Second, as stated above, you can expect to receive your Year 1 payment within 4-8 weeks of completing your initial MU period (90 consecutive days) and attesting successfully.


Third, however, your payment could be withheld until you do enough Medicare billing to qualify for the maximum $18K. This is where attesting at the beginning of the year may not be advantageous. If your Medicare volume is low and you don't achieve the $24K threshold until later in the year, then attesting early will not get you your money earlier.


Time is Your Friend.
The flip side of the hold-off argument is that there are other reasons to start early. Why begin your 90-day MU period as soon as possible? As some have already seen, you may find it harder to embrace EHRs than you thought. You can face learning challenges - your own, or on the part of staff. You may need significant workflow adaptations - don't underestimate how far-reaching this is. You may need to work with your software vendor to get numerators and denominators or Clinical Quality Measures reporting properly. 


Bottom line: expect the unexpected. Demonstrating Meaningful Use is not a plug 'n play operation. Give it time. The more the better.


Alistair Jackson, M.Ed.