by J. Gordon Wright, MD

It is easy to get muddled about the EMR Incentive program. This should be no surprise to anyone since it is a program written by our Federal Government. It has many complexities, double-speak and nuances like Stage I, Stage II and Stage III, Medicaid vs. Medicare programs, undefined terms, and a welter of confusion and jargon.

In an attempt to reduce the 864 pages of the federal register that describe the program to its simplest terms, here is some “best practices” advice to assist you with the practical steps needed to complete your “Pathway to Payment” (if you desire, you can read all 864 pages of the federal register that describes the program here).

Please note that in creating this summary, the following three assumptions are made:

Assumption #1

You would rather participate in the Medicare program than the Medicaid program. This assumption is made because most Phlebologists do not see enough Medicaid patients to qualify for the Medicaid program, as it must be a minimum volume of 30% of your patients.

Assumption #2

You would like to do this with as little change to your normal clinical workflow as possible, and with as little effort as possible.

Assumption #3

You will be able to bill at least $24,000 of allowable charges to Medicare during your self-proclaimed “reporting period,” which can be as short as 90 days, or as long as a year. These are reasonable assumptions that may be applied to the vast majority of physicians who have dedicated at least half of their practice time to phlebology.

For physicians who practice Phlebology less than half the time, some of these assumptions are not applicable, so it may be necessary to seek advice from others who understand your particular situation better. For the typical phlebologist, however, the assumptions above and the advice below are likely applicable and appropriate to your practice.

The government has set aside $19 billion dollars for direct payments to physicians in this program, up to a maximum of $44,000 for physicians who participate in the Medicare program, $18,000 of which is available per physician in the first year of participation. Since 2011 and 2012 are the only two years you can enroll in this program and start your “First Year,” the focus of this article will be on the steps involved in getting started with your “First Year” and getting the $18,000 in your pocket.

What can I do RIGHT NOW?

First, analyze your billing and collections system for each and every physician in your practice who will be applying for incentive money, so you can get an estimate as to how long it normally takes each physician to bill $24,000 of allowable Medicare charges. Please note that this is not a required step, and nothing in the CMS rules and regulations will mention it. It is just a very smart step and tremendously useful in getting you oriented and giving your practice some definite deadlines and plans for collecting the incentive money.

In some practices, the amount of time it takes to bill $24,000 of allowable Medicare charges per physician is always less than 90 days. In other practices, it might take six months or more. You need to have a reasonable estimate as to how long it will take so you can plan out your “Reporting Period” before you proclaim the start of your “Reporting Period.”

If it takes each physician in your practice less than 90 days to submit at least $24,000 in allowable Medicare charges, then the latest you should start your “Reporting Period” is October 1st of the year you want to be your “First Year,” which would probably be this year.

On the other hand, if it typically takes a physician six months to submit $24,000 in allowable Medicare charges, then that physician should start his or her “Reporting Period” no later than July 1st of the calendar year you want to be your “First Year.”Next, go through the following checklist and make sure you qualify as an eligible provider:

• You must be a “participating provider” with Medicare. If you bill and collect from Medicare and get paid according to the normal Medicare fee schedule, you are a participating provider. If you are not sure, contact your billing service or CMS.
• Make sure you have an NPI number, and that you know what it is.
• Make sure you are registered with the CMS’s “Provider Enrollment, Chain and Ownership System” (PECOS). Even if you are a Medicare participating provider and you have an NPI number, you might NOT be registered with PECOS. You can find out by going to the PECOS website. Then, make sure you have a PECOS User ID and Password or an NPPES User ID and Password.
• For those that don’t remember their PECOS User ID and Password and it takes several days of phone calls and emails to recover it, so start now if you do not have it. Similarly, you must have a National Plan and Provider Enumeration System (NPPES) web user account. Please note that your NPPES web account ID and Password are identical to your PECOS User ID and Password, so if you have one, then you have the other and do not need to bother looking any further.

Also please note that just because you have an NPI, it does NOT necessarily mean that you have an NPPES/PECOS web user ID and password. If you have neither an NPPES nor PECOS web user account and password, go to NPPES website to create an NPPES web user account and password. You will use your NPPES/PECOS user ID and password to log into the cMS website which has been set up for Registration for the Incentive Program, and attestation.

Now, you can Register for the Program! Registration is only available online. Log into the CMS website and register for the EMR Incentive Program.

Note: You do NOT have to have purchased a certified EMR before you register for the Incentive Program, but you must have purchased a certified EMR before you can attest that you have achieved Meaningful Use of said certified EMR. When you purchase a certified EMR, you should receive an identifying number for the certified EMR which is kept in the NPPES database, along with your NPI number. You will be required to enter the EMR identifying number along with your NIP on the attestation website, which you get to from this same registration website.

POST REGISTRATION TASKS

If you have completed the above tasks, you are ready to implement a certified EMR product. This should be done no later than October 1, 2012, or October 1, 2011 if you want to have your “First Year” in 2011.

Once you have purchased your certified EMR, installed it, and learned how to use it, then you must use it in a meaningful way for at least 90 days, or until you end your “Reporting Period” which has to be no later than December 31, 2012 at least 90 days after you have purchased and started using your certified EMR Product (and no later than six weeks after your “Reporting Period” has ended) go back to the CMS website and click the “attest” tab so you can attest to CMS that you have been using your certified EMR product and you are now requesting that CMS ends your “Reporting Period” for the First Year.

Congratulations!

You are 4-6 Weeks Away from $18,000! To verify your attestation, CMS will then look into its database and calculate the dollars of allowable charges you have submitted starting on the date your EMR vendor says you purchased the certified Product, and ending on the date you requested that CMS end your “Reporting Period.”

Caveat: The amount of money that CMS will send you will be the lesser of 75% of the allowable charges submitted to Medicare, or $18,000. To reach the maximum allowable payment, you need $24,000 in allowable charges during your “Reporting Period.” Because of this, you should try to establish a way of verifying this with your billing service before you end your reporting period by submitting your attestation.

While these steps may seem daunting, the key is to select an EMR that will actually help you through this process without overly interfering with the normal workflow of a phlebology practice, and to work through the process one step at a time. a systems-based approach to implementation will result in faster recovery of reimbursement dollars. Combined with research on your part to determine the best system for your practice, taking the first steps toward EMR implementation today can ensure maximum return of the government’s incentives tomorrow.