In 2011, the Centers for Medicare and Medicaid Services’ (CMS) EHR Incentive Program began, otherwise known as “meaningful use,” which allowed dermatologists to collect up to $44,000 in incentives over five years under Medicare, or up to $63,750 over six years under Medicaid. The final year to begin the program and be eligible for incentives was 2014.
Starting in 2015, dermatologists and other physicians who did not participate in adopting certified EHR systems and become meaningful users of this technology risk receiving reduced Medicare payments.
You must participate in the program two years preceding the penalty year to avoid the penalty.
Additionally, exemptions from this penalty are available for physicians who lack availability of Internet access, are newly practicing physicians, face unforeseen circumstances (e.g., natural disaster), or have little interaction with patients (e.g., dermatopathologists).
For detailed information on the meaningful use reporting requirements, please visit the Online Learning Center.
CMS defines eligible providers (EP) for the meaningful use program as the following:
- Provider who is a doctor of medicine or osteopathy.
- Doctor of dental surgery or dental medicine.
- Doctor of podiatry.
- Doctor of optometry.
- Chiropractor who is not hospital-based.
A Medicaid-eligible provider is defined as:
- A physician who is not hospital-based and has a minimum of 30 percent of their patient volume comprised of Medicaid patients. Pediatricians may have 20% of their patient volume comprised of Medicaid patients.
- A nurse practitioner.
- A certified nurse-midwife.
- A dentist.
- A physician assistant who furnishes services in a federally qualified health center (FQHC) or rural health clinic (RHC) that is led by a physician assistant.
Registration and attestation
The first step to participating in the meaningful use program is to ensure you select an EHR software program certified for meaningful use. Dermatologists can register for the meaningful use program on the CMS website. Before registering, you must be enrolled in the Medicare Provider Enrollment, Chain, and Ownership System (PECOS) and have a National Plan and Provider Enumeration System (NPPES) username and password.
After your practice has finished performing all meaningful use measures for that year, you must log back into the CMS website to attest.
CMS has provided an appeals process to physicians who wish to contest their meaningful use incentive payment. You may apply for this appeal if you were unable to receive the meaningful use payment or if you had your incentive payment revoked due to an audit or other issue.
The form requires physicians to provide their contact information, reason for the appeal, and supporting documentation. Submit your completed form to firstname.lastname@example.org.
Download the appeal request form
CMS has up to six years to audit any documentation for meaningful use, so this information should be securely stored for at least a decade.
One of the most common ways a physician can be audited is if their denominators for multiple measures do not match. For example, multiple measures have a denominator of unique patients. If this denominator is not the same for each measure that requires it, the physician will be at a higher risk for audit. CMS requests that practices save any information supporting their attestation through the use of screen shots as well as data reflecting clinical quality measures.