While the question is simple – how do I avoid Medicare penalties? – the answer is complex. All who plan to attest during 2014 (i.e. after 28 Feb 2014) must attest by 1 Oct 2014 to avoid 2015 penalties.
Only EPs eligible to participate in the Medicare EHR Incentive Program, who also bill Medicare Part B allowed charges, are at risk for the payment adjustments.
|Eligible Professionals for the Medicare EHR Incentive ProgramThese are the only clinicians at risk for the Medicare payment adjustments to their Medicare Part B allowed charges|
|Doctor of medicine or osteopathy||MD or DO|
|Doctor of dental surgery or dental medicine||DDS or DMD|
|Doctor of podiatry||DPM|
|Doctor of optometry||OD|
|Chiropractor (and a doctor)||DC|
Incentive Reduction – By not attesting in 2013 an organization’s maximum Medicare incentive is decreased by $15,000 per EP (Total of $24k vs. $39K)
Calendar Year (CY) for which EP Receives an Incentive Payment
|MEDICARE INCENTIVES CALENDAR||
|Incentive Payment Year||CY 2011||CY 2012||CY 2013||CY 2014||CY 2015 and later|
Penalties Avoidance – To avoid the 1% payment adjustment in 2015, eligible professionals (EPs) that are in year one of Stage one Meaningful Use (Y1S1) may attest to Meaningful Use (and submit clinical quality measures) by October 1, 2014 for either the Medicaid or Medicare EHR Incentive Program.
Changes required of 2014 Attesters – There are several changes in 2014 that will impact eligible professionals (EPs) that are attesting to Stage 1 Meaningful Use. Most notably the new EHR requirement to 2014 Certified EHR Technology. Check with your EHR vendor to make sure they are certified for Stage 2 or seeking certification before 2014.
This CMS website provides a timeline for Stage 1, 2, 3 for providers who are planning to attest: http://cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Participation-Timeline.html.