Physicians planning to participate in the Medicare Electronic Health Record (EHR) Incentive Program must begin their 90 days of meaningful use by Oct. 1 or they will forfeit $5,000 of the maximum $44,000 bonus. Physicians who begin the program in 2013 will be eligible for only $39,000 over the next four years.   

Physicians in the program must attest every year of the five-year program to continue receiving meaningful use incentive payments. Attestation is the process by which a physician proves to the Centers for Medicare & Medicaid Services that he or she meaningfully uses an EHR. For example, if a physician attested in the 2011 payment year but does not in 2012, he or she forfeits the 2012 payment and cannot make it up the next year. The physician can attest again in 2013 and receive the third payment-year incentive.  

Physicians attesting for payment years 2011, 2012, and 2013 must meet stage 1 meaningful use criteria. The more-advanced stage 2 meaningful use will be required of participants beginning in 2014. CMS released the final stage 2 rules  Aug. 23. Unfortunately, the government did not accept many of the recommendations TMA made. TMA staff is examining the rules and will continue to guide Texas physicians on what they need to do to continue receiving EHR incentive funds. Stage 3 meaningful use rules are not yet proposed and likely won't be introduced until 2013. TMA will apprise you of the rules as they become available. 

Physicians participating in the Medicaid EHR Incentive Program can skip years during the attestation process. The six-year Medicaid EHR Incentive Program pays out until 2021. Physicians can attest now and then skip a couple of years before having to attest for their second year of the program. The caveat in waiting too long is that physicians would have to comply with the more-advanced stages of meaningful use. 

The EHR incentive program is complex in requiring physicians to meet varied and more difficult stages as they progress through the multiyear program. To help, the Office of the National Coordinator for Health Information Technology (HIT) established regional extension centers (RECs) to provide onsite HIT consulting in physician practices.   

A recent government accountability office (GAO) report indicated that physicians were twice as likely to receive their incentive payments when they used the REC program. Visit the TMA REC Resource Center to find the REC serving your geographic region.    

For questions regarding attestation or other HIT needs, contact TMA's Health Information Technology Department at (800) 880-5720 or by email.  

 Action, Sept. 5, 2012