EHR adoption bonus and penalties

CMS releases final EHR stage 2 rule

On Aug. 23, CMS released its final rule for stage 2 of the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. CMS says the rule will enhance the health information exchange between providers, and promote patient engagement by giving patients secure online access to their health information. Learn more about the final rule here.

The Patient Protection and Affordable Care Act does not specifically contain provisions related to electronic health records, it is seen as an important aspect of the broader health system reform milieu. An incentive program to expand the use of EHRs is established in the HITECH provisions of the American Recovery and Reinvestment Act. Details about the Medicare and Medicaid incentives for the meaningful use of EHRs and tips for vendor selection and implementation can be found at the Academy's health information technology (HIT-kit) resource center.

The Academy continues to advocate for, educate, and engage members to ensure that the health information technology (HIT) needs and priorities of dermatology are being addressed and met. Recent federal legislation and electronic health record (EHR) developments have created new opportunities for dermatology. The American Recovery and Reinvestment Act of 2009, better known as the economic stimulus package, will allow eligible dermatology practices that participate in Medicare and Medicaid to qualify for financial incentive payments to adopt health information technology (HIT).

 

Medicare incentives and penalties

Qualifying dermatology practices can be reimbursed up to $44,000 for adopting a certified electronic health record (EHR) as long as they have at least $24,000 in Medicare allowed charges per year and use their certified EHR in a meaningful way based on three broad requirements:

  • The EHR must be certified through the Office of the National Coordinator.
  • The EHR must provide electronic exchange of health information.
  • Eligible dermatologists must submit clinical quality measures and potentially other measures yet to be defined.

The five-year Medicare incentive payments schedule is based on 75 percent of the physician's Medicare allowed charges or a maximum of the following. Penalties will apply beginning in 2015.

Year of EHR adoption

Payment in 2011

Payment in 2012

Payment in 2013

Payment in 2014

Payment in 2015

Payment in 2016

Total incentive Penalty*
2011 $18,000 $12,000 $8,000 $4,000 $2,000
$0
$44,000 0 percent
2012   $18,000 $12,000 $8,000 $4,000 $2,000 $44,000 0 percent
2013     $15,000 $12,000 $8,000 $4,000 $39,000 0 percent
2014    
$12,000 $8,000
$4,000
$24,000
0 percent
2015               1 percent
2016               2 percent
2017 and beyond
              3 percent

*Percentages based on Medicare Part B allowed charges.

CMS also has developed a bonus incentive program if a prescriber successfully e-prescribes (eRx). For the first three years, CMS will give a bonus payment in addition to the covered Medicare Part B charges. However, after 2012, CMS will begin instituting a penalty if a provider fails to e-prescribe.

 Year of E-Rx adoption
Incentive*
Penalty*
 2010 2 percent
0 percent
 2011 1 percent
0 percent
 2012 1 percent
1 percent
 2013 0.5 percent
1.5 percent
 2014 and beyond
0 percent

2 percent


*Percentages based on Medicare Part B allowed charges.

Additional EHR resources