Q/A for Ambulatory Providers

By: Chris DeMeo
The Digital Office HIMSS
Monthly, 2011

Q. Is it better to go ahead and attest for Medicare when a doctor has achieved the meaningful use criteria, although he has not reached the $24,000 mark to qualify for the $18,000 incentive?

Not all doctors in our clinic will achieve the $24,000 mark for the entire year. So, in that case, would the Centers for Medicare and Medicaid Services (CMS), to cut only one check, wait and payout after the year is over if a doctor attests but has not achieved the $24k mark?

It is my understanding that CMS uses its database to see if the $24,000 mark has been met. Physician Practice Group Manager, Louisiana.

• There is not much of a track record for the process yet, but it would appear advantageous to submit for payment once meaningful use is achieved, even if the $24,000.00 "threshold" has not yet been reached.

Here's why:

• Keep in mind that the incentive payment is 75% of allowed charges, so, to get the maximum $18,000, an EP would need $24,000. However, if the EP does not bill $24,000 in allowed charges, he or she still gets 75% of whatever he or she does bill.

For EPs that do not reach the maximum incentive, CMS expects to issue an incentive payment for the EPs at 75% of allowed charges for that year in March 2012 (allowing 60 days after the end of the 2011 calendar year for all pending claims to be processed).

• It takes 4-8 weeks to process the payment from the date of attestation, so if the EP crosses the threshold during that time, he or she may be able to streamline the payment.
• CMS says EPs will get paid through the taxpayer identification numbers (TINs) they registered under in the same way claims payments are made.

This leads me to believe that CMS will not hold the payment while waiting for all EPs in the group to reach $24,000. I believe you are correct that CMS uses its database to see if the $24,000 mark has been met.

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