Meaningful Use Registration, Timeline, and Penalties Simplified

Some meaningful use deadlines for Medicare are approaching.  I can tell because I am hearing from practices that want to choose and implement an EHR before July 1.  Here is what I tell them, and some of the key deadlines that I think all practices should be aware of:

Registration, Reporting Periods, and Penalties
An eligible professional can register for meaningful use without specifying an EHR.  It's a good idea to go ahead and register as soon as possible.  The certified EHR you are using can be entered later.

Medicare payments for services rendered in 2015 will be reduced by 1 percent for eligible providers (EPs) who have not successfully attested to the meaningful use of a certified EHR by Oct. 1, 2014.  That means:
• The last possible beginning date for the reporting period is July 1, 2014.
• The eligible professional must have all the data ready and attest no later than Oct. 1, 2014.  EPs can attest earlier than October 1 for reporting periods ending April 30 or June 30.

Medicare Incentives
The maximum Medicare incentive for a first time attester in 2014 is $11,760 ($12,000 minus $240 for sequestration).

Getting the maximum amount requires Medicare allowable charges for covered services furnished by the EP during the reporting period of $16,000.  The incentive is limited to 75 percent of the EP's Medicare allowable charges for covered services.

Rough Cost/Benefit Analysis
Failure to successfully attest to Stage 1 by October 1 will cost each EP the 2014 incentive payment plus the 2015 Medicare penalty.  The size of both depends upon the EP's Medicare volume. 

For the sake of simplicity, let's assume the EP expects to bill $60,000 in Medicare allowable charges in the third quarter of 2014 and $250,000 in Medicare allowable charges in 2015.  The direct impact to Medicare payments to the EP is:
• 2014 Meaningful use incentive:  75 percent of $60,000 = $45,000, capped at $12,000
• 2015 Medicare penalties:  .01 percent of $250,000 = $2,500
• Total reduction in CMS payments:  98 percent of ($12,000 + $2,500) = $14,210

Is the possibility of realizing the $14,210 worth the potential damage to your practice that an ill-considered choice and hurried implementation of an EHR can inflict?  The costs of a rushed implementation include:

• Decreased productivity
• Overtime
• Patient defections

Even worse, poor implementations almost never get fixed.  The practice lives with the problems in perpetuity, or until the original investment in an EHR is abandoned and the practice starts again.  One practice I know is still waiting to get its patient registration times below 45 minutes, and it installed its EHR 15 months ago.  Sad to say, 45 minutes is its new normal.

My Advice
Give yourself a chance to make a good decision. At the very least, think about what you want in an EHR before scheduling demos. If you don't have a benchmark against which to evaluate the alternatives, I can promise you that they all will look wonderful.  You will also be in the position of trying to compare apples to oranges.

You may choose a system that can let you go live in a few minutes or days.  Remember you can do that and start the clock on the reporting period without actually transitioning your practice immediately.  The percentage thresholds for Stage 1 are low enough that you can take some time to ease the transition and still satisfy them.

Don't skip on hardware and communication infrastructure.  Buy at least what the vendor recommends.  I would recommend buying more speed and memory than the vendor requires.

If at all possible, spend some money on some help.  Vendors will say they can manage the implementation.  They can, as the implementation relates to their products.  What they generally do poorly is manage the implementation as it relates to the way the practice operates.  An outsider is invaluable for this function.

MD may stand for make a decision, and quick decisions are often necessary.  The selection and implementation of an EHR is not well done in a hurry.