By now we all (hopefully) know the ABCs of the CMS EHR Incentive Program: Registration – Meaningful Use of Certified EHR Technology – Attestation. After attestation you hope to get a check so you can go out and buy your second iPad plus a few other toys. Maybe even take a trip to that all-inclusive resort in Cancun. But does it have to be that way? Does an eligible provider have to register to begin the process?
Surprisingly, the answer is no. The Medicaid program is a bit quirky in that in the initial year an eligible provider doesn’t have to actually be using an EHR, meaningfully or otherwise. On the Medicare side those Washington meanies actually make you do something to get the incentives for the initial year. However, you can get that handy dandy certified EHR, use it enough for 90 consecutive days, and then perform the required registration. You can even register and then attest on the same day. CMS would of course 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 until February 29, 2012 if you want to to begin the process.
February 29, 2012 is the last day for eligible professionals to register and attest to receive incentives for 2011.
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Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. As one hospital CEO stated, “we were notified by CMS that the adverse audit decision was being overturned and we did not have to return the 2011 EHR Incentive Payment. I would recommend the services of Mr. Tate and EMR Advocate in the event your facility is notified that it will be subject to a Meaningful Use audit or your facility is audited, or you have an adverse outcome and need to file an appeal." He blogs at Meaningful Use Audits. If you are a hospital with a question about the MU audit and appeal process, email him at: [email protected]
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