Medicaid Ehr Incentives – A Learning Experience

By straightaway almost everybody that has whatever remote involvement inward Health Care is aware of the much publicized incentives made available to wellness aid providers for the adoption too meaningful usage of certified EHR technology. The most quoted number is $44,000 to hold upwardly paid past times CMS to Medicare physicians. Practically every EHR vendor website is adorned alongside a Flash banner “educating” doctors on this cash windfall, too practically every HIT detractor is alert that the incentives are but a pittance compared to the existent costs of ownership of a certified EHR. Very rarely does anybody acquire into the intricacies of the available incentives for Medicaid providers, which are almost 50% higher than Medicare too involve clinicians providing aid to our most vulnerable citizens. However, in that place is much to larn from the construction of the Medicaid incentives program.

The HITECH statute sets forth a “net” average allowable toll for purchasing too implementing an EHR at $25,000 for the offset twelvemonth too $10,000 for subsequent years. Of this “net” allowable cost, the Secretary of HHS is authorized to pay Medicaid Eligible Providers upwardly to 85% inward stimulus incentives for a full of half dozen years. It appears that the Government is nearly to pay you lot 85% of your EHR costs for the adjacent half dozen years, which is a pretty expert deal. Looks, however, tin hold upwardly deceiving. As whatever early on adopter of EHR knows, the full toll of ownership for an EHR over half dozen years is good over the “net” allowable of $75,000 laid forth inward the HITECH Act, too Congress knew that too. This is why the statute instructs the Secretary of HHS to determine the actual average allowable costs of EHR:

“(C) For the purposes of determining average allowable costs nether this subsection, the Secretary shall written report the average costs to Medicaid providers described inward paragraph (2)(A) of purchase too initial implementation too upgrade of certified EHR applied scientific discipline described inward paragraph (3)(C)(i) too the average costs to such providers of operations, maintenance, too usage of such applied scientific discipline described inward paragraph (3)(C)(ii). In determining such costs for such providers, the Secretary may utilize studies of such amounts submitted past times States.”

The Secretary indeed researched too studied the actual costs of EHR adoption and, inward the CMS terminal rule, came upwardly alongside an average allowable toll for purchasing too implementing an EHR of $54,000 for the offset twelvemonth too $20,610 for subsequent years, putting the average toll of ownership for half dozen years at $136,440 per Eligible Provider. This is closer to reality, although roughly would enquiry if the Secretary brought into describe of piece of employment concern human relationship loss of productivity land calculating these numbers. At this point, confusion sets inward for most folks. If Congress already decided that they would pay no to a greater extent than than 85% of $75,000, why is the Secretary calculating the actual costs too showing us how inadequate the incentive payments actually are? The response lies inward the piddling give-and-take “net”.

In the unlikely number that somebody, presumably the molar fairy, gives you lot roughly coin to purchase an EHR, that amount of coin must hold upwardly deducted from the $54,000 for the offset year, too your incentive amount is calculated every bit 85% of the remainder: First twelvemonth incentive = ($54,000 – Cash gift for EHR)*85% -or- First twelvemonth incentive = $25,000*85%, whichever 1 is smaller. The same logic applies to subsequent years. The only enquiry straightaway is what constitutes a cash gift for EHR technology. Well, the CMS terminal dominion is pretty clear on that. First, State too local regime contributions create non count. General grants for improvements create non count either. If you lot are employed past times a Federally Qualified Health Center (FQHC) or Rural Health Clinic (RHC) or anybody else, too your employer purchases an EHR for you, that doesn’t count every bit a cash gift for EHR, too neither create whatever in-kind donations from vendors or other entities. Basically, unless someone non mentioned to a higher house hands you lot a wad of dollar bills wrapped inward a notation stating “This cash is exclusively for your EHR, doctor”, too that wad of dollar bills is greater than $29,000, your stimulus incentive volition non hold upwardly reduced.

You create convey to demo CMS that you lot paid for at to the lowest degree 15% of the "net" allowable EHR toll alongside your ain coin ($3,750 inward the offset twelvemonth too $1,500 inward subsequent years), but hither is the beauty of the terminal rule: all those contributions from State, local governments, employers too in-kind donors, which did non count for calculating your “net” allowable cost, tin hold upwardly used to augment, too solely substitute for, your out of steal 15%. This is 1 of the most magnificent examples of bureaucracy at its really best, since when all rules too exclusions are counted, it seems that practically everybody volition hold upwardly eligible for the maximum incentive of $21,250 inward the offset twelvemonth too $8,500 inward subsequent years. It is worth noting that these amounts don’t encompass fifty-fifty one-half of the Secretary’s estimated average EHR adoption costs.

How nearly Eligible Providers who are salaried employees, either inward a cost-based FQHC or RHC, or whatever other fee-for-service entity? Most of these doctors assume that they convey to assign their incentive payments to their employer, who provided them alongside the EHR. The CMS terminal dominion clarifies that you lot tin voluntarily assign your incentives to your employer, but you lot most sure enough create non convey to create so.

“We believe that, inward accordance alongside 1903(t)(6)(A) of the Act, an EP could reassign payment to a TIN associated alongside his or her employer or the facility inward which she or he works. …  Any reassignment of payment must hold upwardly voluntary too nosotros believe the determination every bit to whether an EP does reassign incentive payments to a specific TIN is an number which EPs too these other parties should resolve.”

Reassignment of incentives to an employer, or whatever other entity promoting EHR technologies, is left to the physician too his/her employer. There are multiple potent warnings throughout the CMS terminal dominion that such reassignment must hold upwardly voluntary too the “States must guarantee that the assignment is voluntary”. For anybody contemplating creative arrangements that volition cut back payments to employed physicians, inward an FQHC for example, to compensate for EHR expenditures, CMS clarifies that “Incentive payments are payments designed to promote the adoption too meaningful usage of certified EHR applied scientific discipline too are non payments for medical assistance provided inward the FQHC. We create non convey the authorization nether this programme to furnish that these funds hold upwardly the footing for the State to cut back its per watch payment to the FQHC.”

In summary, if you lot are a Medicaid Eligible Provider inward mortal practice, you lot tin facial expression $63,750 from Medicaid over the adjacent half dozen years. If you lot are an employed Medicaid Eligible Provider, you lot should clarify alongside your employer what the expectations are. There is in all likelihood nil regarding incentives inward your contract, too land you lot could let your employer to collect your incentives, nil inward the CMS terminal dominion mandates that you lot create so, too quite the contrary is true. You may desire to consider that an EHR volition most probable cut back your productivity initially, too perchance for longer than you lot expect. If you lot are practicing inside a cost-based facility, your income volition hold upwardly adversely affected past times the EHR adoption process, too it may brand perfect feel to retain your incentive payments every bit partial compensation for loss of income, fifty-fifty if your employer paid for your EHR.