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CMS Releases 2018 EHR Incentive Program Fact Sheet

As part of the American Recovery and Reinvestment Act of 2009 (ARRA), Congress established payment adjustments under Medicare for certain eligible clinicians (eligible clinicians include doctors of medicine or osteopathy, doctors of dental surgery or dental medicine, doctors of podiatric medicine, doctors of optometry, and chiropractors)  that are not meaningful users of Certified EHR Technology. EPs that do not successfully demonstrate meaningful use for an EHR reporting period associated with a payment adjustment year will receive reduced Medicare payments for that year. The Medicare payment adjustments sunset in 2018 for EPs pursuant to the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). 

If a clinician is eligible to participate in the Medicare EHR Incentive Program, by law they must successfully demonstrate meaningful use in either the Medicare EHR Incentive Program or in the Medicaid EHR Incentive Program to avoid a downward Medicare payment adjustment. Medicaid clinicians who do not furnish covered professional services under Medicare are not subject to these downward payment adjustments. Since 2011, more than 400,000 clinicians have received incentive payments under the Medicare and Medicaid EHR Incentive Program. 

2017 Performance Period and the MIPS Replacing EHR, PQRS, and VBM Programs
The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) combines certain aspects of the existing Medicare EHR Incentive Program, Physician Quality Reporting System (PQRS), and Value-Based Payment Modifier (VBM) programs into the Merit-based Incentive Payment System (MIPS), starting with the 2017 MIPS performance period. MIPS payment adjustments are applied to Medicare Part B payments for items and services furnished two years after the performance period, with  2019 being the payment adjustment year for the 2017 performance period. 

By law, MIPS includes four categories of eligible clinician performance, contributing to a MIPS final score of up to 100 points (relative weights are indicated for the 2017 performance period and associated 2019 payment adjustment year):

For 2017, clinicians who successfully demonstrated meaningful use in a prior year will no longer report to the Medicare EHR Incentive Program, although clinicians who are eligible for Medicaid EHR incentive payments will continue to attest to their state to earn an incentive payment. Clinicians who previously reported under the Medicare EHR Incentive Program will instead report to MIPS for 2017, and are subject to the program requirements and payment adjustments of that program. However, if a clinician has not successfully demonstrated meaningful use in a prior year and wants to avoid the 2018 downward payment adjustment under the Medicare EHR Incentive Program, the EHR reporting period was a consecutive 90-day period in 2017, and the clinician must have attested to meaningful use no later than October 1, 2017.  As mentioned above, clinicians who would have been first-time participants in the Medicare EHR Incentive Program in 2017 may have been eligible to apply for a one-time hardship exception by October 1, 2017, in order to avoid the 2018 downward payment adjustment. 

EHR Incentive Payments for Eligible Professionals 
Eligible clinicians who successfully demonstrated meaningful use of certified EHR technology could have received incentive payments under Medicare for up to five consecutive years throughout the duration of the program.  The program started in 2011, and payments continued under Medicare through 2016 with no Medicare incentive payments available after 2016 pursuant to the statute. 

A clinician demonstrates meaningful use by successfully attesting through either the Centers for Medicare & Medicaid Services (CMS) Medicare EHR Incentive Programs Attestation System (https://ehrincentives.cms.gov) or through its state's Medicaid EHR Incentive Program attestation system. 

Clinician payment information can be found at www.cms.gov/EHRIncentivePrograms.

2018 EHR Eligible Professional Payment Adjustment 
The EHR Incentive Program downward payment adjustment began to apply to Medicare Physician Fee Schedule  payments for covered professional services furnished January 1, 2015, through December 31, 2015.  The payment adjustment amount is established by statute for a specific calendar year and continues through the end of CY 2018. The table below illustrates the application of the reduced  amount. 

Payment Adjustment Background

Clinicians Who Are Not Meaningful EHR Users
Clinicians who received the ePrescribing downward adjustment for not being a successful electronic subscriber in 2014 and were subject to the EHR downward adjustment in the Medicare EHR Incentive Program in 2015 received an additional 1% EHR downward adjustment for 2015 only. This resulted in those clinicians receiving 98% of the amount that would otherwise apply to such services during 2015. 

Clinician is not subject to the payment adjustment for ePrescribing in 2014

2015

2016

2017

2018

% of the MPFS amount

99%

98%

97%

97%

 

Clinician is subject to the payment adjustment for ePrescribing in 2014

2015

2016

2017

2018

% of the Physician fee schedule amount

98%

98%

97%

97%

 

2018 EHR Exceptions Process for Clinicians 
Clinicians may apply for significant hardship exceptions to avoid the payment adjustments described above.  Such exceptions may be granted for certain categories of clinicians, or on a case-by-case basis, and only if CMS determines that compliance with the requirement for a clinician to be a meaningful EHR user would result in a significant hardship. 

Information on how to apply for a hardship exception is posted on the CMS EHR Incentive Programs website (www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentive
Programs/PaymentAdj_Hardship.html
). 

Applications must be submitted no later than July 1st of the year before the applicable payment adjustment year. For example, for the 2018 payment adjustment, a clinician must have submitted a hardship exception application by July 1, 2017. 

Applicable Hardship Exceptions Categories for Clinicians:

Anesthesiologists, pathologists, and radiologists may receive hardship exceptions without applying based on their primary specialty as listed in the Provider Enrollment Chain and Ownership System (PECOS) six months prior to the first day of the year in which the payment adjustment would otherwise apply. 

In addition, a clinician will be exempted from the application of the downward payment adjustment for 2018 if compliance with the requirement for being a meaningful EHR user is not possible because the certified EHR technology used by the clinician has been decertified under ONC's Health IT Certification Program. Applications requesting this exception must have been submitted no later than October 1, 2017.                                                                                                                         

2018 EHR Incentive Program and Payment Adjustments
Clinicians must demonstrate meaningful use every year in order to avoid Medicare downward payment adjustments in the years identified above. For example, a clinician that demonstrated meaningful use for the first time in 2013 would have avoided the payment adjustment in 2015, but would have had to demonstrate meaningful use again in 2016 in order to avoid the payment adjustment in 2018. It is important to note that 2018 is the last year of downward payment adjustments for clinicians in the Medicare EHR Incentive Program. 

There are approximately 180,000 clinicians subject to a downward payment adjustment in 2018 under Medicare for failing to demonstrate meaningful use. 

For more information on the Medicare and Medicaid EHR Incentive Program visit www.cms.gov/EHRIncentivePrograms

— Source: Centers for Medicare & Medicaid Services