Medicare EHR Attestation When Switching Practices Mid-Year – 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.

This week’s post will answer a Medicare question posed by a reader in response to Jessica’s post last week on Medicaid EHR Attestation with Multiple Practices. The reader asked about a physician who switches from one practice to another in the middle of year 2, but the answer below would also apply to a physician who works part-time at two (or more) practices.

“What about a Medicare EP who successfully attested for year one with her former employer and now works with us. Neither employer has enough information to report a full 12 months of info for her. Do we still attest for year two and fail it all or can we skip a year? And is it ok for the first employer to receive the first payment and we claim the rest? So complicated! Thanks for any input/help!!!”

Although the situation does make it more complex to attest, it does not mean that she cannot earn an EHR incentive this year. Incentives are tied to the physician—not the group—via the physician’s individual NPI number, regardless of whether the payment was made directly to the physician or assigned to the group. Therefore, even if the physician assigned payment to his former group last year, it is perfectly acceptable for her to assign payment to her new group this year. 

A physician who successfully attested and earned an EHR incentive in 2011 must report for the full calendar year in 2012 in order to earn the second payment. However, the information does not have to come from just one practice for the entire year. As long as the physician uses a certified EHR at both practices, she would simply have to report on all of the meaningful use requirements with data from both practices, combining the numerators and denominators for each measure when attesting. (For an explanation of how to report, see read CMS’s FAQ #3609.) She would also have to enter both EHRs into the CHPL website and generate a different Certification ID Number. 

If for some reason, the physician does not elect to pursue the 2012 incentive, there is no need to attest and fail this year. She can simply forego the second payment and start again with the third year’s incentive next January.

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

  • Thanks so much for answering my question! It is very helpful to me and I’m sure more providers/groups will run into this issue as time goes on through the years of MU and providers change employers over the course of time.

  • What do you do if your prior practice (who was using certified EHR technology and tracking meaningful use data) refuses to hand over the data? It is my understanding that since we will be reporting for the full year, it is required to use data from both practices. Without this data, my physician cannot get the incentive payments he is entitled to. Thank you for your input on this topic.

  • Is there any legal requirement of an employer to release the information to the physician wanting to attest?
    Thanks, Kara

  • Kara,
    Depends on your contract. If I were in your shoes, I’d reach out to Mark Anderson from http://www.acgroup.org/ He’s been successful at negotiating the release of data from EHR vendors holding it hostage. It will depend on a lot of factors, but I think he’d be able to help guide you.

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