EPs Switching EHR Incentive Programs

Changing Between EHR Incentive Programs

Switching programs does not mean double dipping.

Recently we received a question that I thought interesting enough to post about. If an Eligible Professional participates in the Medicare EHR Incentive program in 2011 and then decides to change to the Medicaid EP EHR Incentive Program in 2012, can the EP collect incentive payments for stage 1 in the new program? Or if the Eligible Professional participates in the Medicaid program in 2011 and then decides to attest to meaningful use in the Medicare program in 2012, can the EP collect incentive payments for stage 1 in the new program?

According to CMS, after an EP qualifies for an EHR incentive payment under one program but before 2015, an EP may switch between the Medicare and Medicaid programs one time. Upon switching programs, the EP will be placed in the payment year the EP would have been in had the EP not switched programs. For example, if an EP decides to switch after attesting to meaningful use of certified EHR technology for a Medicare Fee-for-Service (FFS) incentive payment for the second payment year, then the EP would be in the third payment year for purposes of the Medicaid incentive payments.

You can find this along with more information on the EHR Incentive Programs for Eligible Professionals in this CMS Tip Sheet.