The Financial Implications of Skipping Years and Switching Incentive Programs – Meaningful Use Monday

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.

A reader posed the following question: What happens if a physician receives a Medicaid EHR incentive in 2011, no longer meets the 30% eligibility threshold for Medicaid in 2012 and therefore elects not to apply for any incentive that year, and then has to switch to the Medicare program in 2013 because his Medicaid volume is still too low to qualify under Medicaid? Below is a follow-up to a prior post, (“Switching Between Medicare and Medicaid Incentive Programs”), that provides the additional information needed to not only answer this particular question, but also to evaluate the financial impact of other scenarios in which a provider might skip years and/or switch between programs. 

Here are the rules regarding switching programs and skipping years:

  • An EP can switch between programs only once after receiving his first incentive payment, and the switch must occur in 2014 or earlier.
  • When an EP switches programs, he is “placed in the payment year he would have been in had he begun in—and remained in—the program to which he has switched.”
  • Medicare and Medicaid treat skipping years differently. Medicare incentives require that payment years be consecutive—so while an EP can skip a year, if he does, he forfeits that year’s incentive permanently. Medicaid incentive payments, on the other hand, can be non-consecutive with no adverse impact on total available revenue.
  • The last year that payments will be available also differs between the two programs. Under Medicare, no payments will be made after 2016, whereas EPs have until 2021 to earn incentives under Medicaid.
  • Although an EP who switches to or from the Medicare program could—under certain circumstances—earn more than the total Medicare incentives ($44,000), in no cases would any EP be paid more than the maximum available under Medicaid ($63,750). 

To get back to the physician in the reader’s question, when he switches to the Medicare program after skipping 2012, 2013 would be considered (and paid as) his third payment year. 

Confused? To analyze the financial implications of switching programs and/or skipping a year under scenarios that might apply to your practice, make a chart and do the math—taking into account the above rules and the schedules of annual incentives.

About the author

Lynn Scheps

Lynn Scheps

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money.

5 Comments

  • We are in the process of changing EMR and the current company is refusing to supply us with any information/backup so the data conversion company can give us options/costs for a data conversion. The two companies we’re looking at have different opinions about whether the data can be converted. They are telling us that it may end up as a PDF file on the DOS, however each patient has separate DOS info plus multiple attachments to their chart. Any direction for me on how to convince the company to give me copy of my data?

  • Brian,
    That’s a loaded question. Unfortunately, I’m swamped at HIMSS. Although, my best recommendation is to find a consultant or company that’s done a lot of these EMR exports and imports. They’ll have the experience and the knowledge to tell you what’s really possible and reasonable in your particular situation. There are some ways around it, because EMR vendors hate to have bad news out in the public about them.

  • “Medicare incentives require that payment years be consecutive—so while an EP can skip a year, if he does, he forfeits that year’s incentive permanently.”

    If a provider skips a year for MU, when they return to MU, must they start over at Stage 1 or continue onto the next stage.

  • Carrie,

    If a provider skips a year, he would return to the program in the incentive year and stage that he would have been in had he successfully attested for the skipped year. For example, if a provider who earned an incentive in 2012 fails to do so in 2013, he would be in his 3rd incentive year and at Stage 2 when he returns in 2014.

    (As an aside, in that particular situation, the provider would be subject to the 2015 1% penalty for failing to demonstrate meaningful use in 2013.)

    Lynn

  • I’m trying to figure out the implications of switching from Medicare (where each year counts, regardless of participation), to Medicaid (where only participation years count). What happens in the following scenario:

    2011 – I do Medicare (Year 1)
    2012 – Skip (Year 2)
    2013 – I do Medicare (Year 3)
    2014 – I switch to Medicaid…

    In 2014, am I in Year 3 or Year 4 under the Medicaid program?

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