Now that the Centers for Medicare and Medicaid Services (CMS) has released its final rule on meaningful use, the agency is preparing the systems that will trigger incentive payments—which physicians will start receiving as early as May 2011.

The CMS will open registration for the incentive program in January. Physicians can begin signing up for the program then.

To sign up, eligible Medicare physicians must have: (1) a national provider identifier and be enrolled in the CMS Provider Enrollment, Chain and Ownership System (PECOS), which validates and tracks the enrollment of providers and suppliers in the Medicare program, and (2) an active user account in the National Plan and Provider Enumeration System (NPPES), which assigns unique identifiers to health plans and providers in exchanging health information.

To begin receiving payments, physicians must verify that they have demonstrated meaningful use of certified Electronic Health Records (EHRs) for 90 days.

Physicians do not have to inform CMS of which certified EHR system they are using until they submit information verifying they have met meaningful use requirements. As a result, physicians may use an EHR that hasn’t yet been certified but that they expect will qualify for certification by the time they verify that they have demonstrated meaningful use for 90 days.

Related articles: CMS will start incentive payments in May 2011

Physicians are not required to treat a minimum number of Medicare patients in order to be eligible for the incentive payments. However, there is a cap on the total EHR incentive available to physicians.

The cap is based on 75% of the allowable Medicare charges for the physician, not to exceed total payments of $44,000 ($48,000 for physicians who practice in a professional shortage area).

So, physicians with lower Medicare volumes may be eligible for a smaller amount.

To clarify, for example, in 2011, the first payment to those physicians who meaningfully using a qualified, certified EHR is $18,000. Therefore, a Medicare provider who charges $24,000 (or more) in Medicare allowable charges is eligible for the $18,000 payment in 2011 (because 75% of $24,000 is $18,000).

Here is the entire flow for all stimulus payments:

Please contact us with any questions or for more information. We can help you find an EHR solution that provides the tools necessary to help you achieve the requirements of the ARRA.