In 2011, the Centers for Medicare and Medicaid Services’ (CMS) EHR Incentive Program began, which allows dermatologists to collect up to $44,000 in incentives over five years under Medicare, or up to $63,750 over six years under Medicaid. Authorized under the American Recovery and Reinvestment Act (ARRA) of 2009, the EHR incentive program is designed to stimulate interest in the adoption of EHRs.
Dermatologists need to meet several requirements to be eligible for the incentive funds, including using a certified EHR system and become a meaningful user, which is explained below. Starting in 2015, dermatologists and other physicians who do not participate in adopting certified EHR systems and becoming meaningful users of this technology will risk receiving reduced Medicare payments. View the payment schedule for participation in the Medicare EHR Incentive Program here.
The penalty for not participating in the EHR Incentive Program begins in 2015. The penalty begins at 1 percent in 2015 and increases to 2 percent in 2016, 3 percent in 2017 and can go up to as much as 5 percent of your total Medicare Part B allowed charges. You must participate in the program two years preceding the penalty year. The following options are available to avoid the penalty in 2015:
Future penalty years will require the following participation schedule.
Additionally, exemptions are available for physicians who lack availability of Internet access, are newly practicing physicians, face unforeseen circumstances (e.g. natural disaster), or have little interaction with patients (e.g. dermatopathologists). Learn how to apply for these exemptions.
CMS defines eligible providers (EP) for the Medicare EHR Incentive Program as the following:
- A provider who is a doctor of medicine or osteopathy.
- A doctor of dental surgery or dental medicine.
- A doctor of podiatry.
- A doctor of optometry.
- A chiropractor who is not hospital-based.
A Medicaid-eligible provider is defined as:
- A physician.
- A nurse practitioner.
- A certified nurse-midwife.
- A dentist.
- A physician assistant who furnishes services in a federally qualified health center (FQHC) or rural health clinic (RHC) that is led by a physician assistant.
To qualify for an EHR incentive payment, Medicaid EPs must not be hospital-based and must have a minimum of 30 percent of their patient volume comprised of Medicaid patients. EPs must also be pediatricians and have at least 20 percent of their patient volume comprised of Medicaid patients or practice predominantly in a FQHC or RHC and have a minimum 30 percent patient volume attributable to needy individuals. Providers only may select one program in which to participate.
The EHR Incentive Program is divided into stages based on when the physician starts the program. Each stage requires different meaningful use objectives and becomes progressively more difficult as the program progresses. View which stage is relevant for each year of reporting here.
View the overall CMS incentives available to providers and overall CMS penalties applicable to providers here.
Registration and attestation
The first step for any provider who wishes to participate in the EHR Incentive Program is to ensure he or she selects an EHR software program that is certified for meaningful use and the dermatology-specific Certification Commission for Healthcare Information Technology (CCHIT) certification.
Dermatologists can register for the EHR Incentive Program on the CMS website. Participants must be enrolled in the Medicare Provider Enrollment, Chain, and Ownership System (PECOS) and have a National Plan and Provider Enumeration System (NPPES) username and password.
The first year you participate in the program, there is a 90-day reporting period. Therefore, the last day to begin the program in your first year of reporting is on Oct. 1 of the reporting year. Participating from Oct. 1 to Dec. 31 will allow the physician to report for 90 days. Every subsequent year requires the dermatologist to report for the full year, except for 2014 when all providers regardless of the stage they are reporting are allowed to report for a 90-day period.
After your practice has finished performing all of the meaningful use measures for that year, you must log back into the CMS website where you registered and attest. View the CMS guide to attestation here. This guide will help you navigate the attestation module.
Please note, CMS has up to 6 years to audit any documentation for meaningful use, so this information should be securely stored for at least a decade. Please note, one of the most common ways a physician can be audited is if their denominators for multiple measures do not match. For example, multiple measures have a denominator of unique patients. If this denominator is not the same for each measure that requires it, the physician will be at a higher risk for an audit. CMS requests that practices save any information supporting their attestation through the use of screen shots as well as data reflecting clinical quality measures. For more information, please visit the CMS website.