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An Eligible Professional (EP), Eligible Hospital or Critical Access Hospital (CAH) that participates in the Medicare EHR Incentive Program and does not meet MU for one participation year is highly encouraged to continue to attest and earn incentive payments for future participation years.
If a participating provider does not successfully attest for a given year, he/she will not be eligible to receive an incentive payment for that year. However, attesting and receiving an incentive payment for a future participation year is based on the provider’s ability to meet MU during that year and not based on success or failure in previous years.
When a provider continues to participate and submit attestation information in subsequent years, the progression through the stages of MU will continue to follow the CMS-established timeline of meeting the MU criteria of each stage for two program years, regardless of whether he/she demonstrates MU in each consecutive year.
For example, if an EP demonstrates the stage 1 criteria for the 1st payment year, but does not meet the stage 1 criteria in the 2nd payment year, the EP will receive an incentive payment for the 1st payment year but not receive the associated incentive payment for the 2nd year.
When the EP proceeds to attest for the 3rd payment year, he/she may be eligible to receive the associated incentive payment if MU is met. However, since the EP has completed the 1st and 2nd program years, the EP will be expected to demonstrate the stage 2 meaningful use criteria to receive payment in the 3rd year, even if he/she did not meet the stage 1 criteria in the 2nd year.
If a provider registers to participate in the EHR Incentive Program for the first year but chooses to withdraw their attestation, the provider may have the opportunity to start over and “repeat” their first year of participation in the Incentive Program if a CMS post payment or prepayment audit has not been initiated. If the provider withdraws their attestation during or after a CMS audit has been conducted, the provider forfeits the ability to reattest as a Year 1 participant and must attest as a Year 2 participant in the next year. Once the provider has withdrawn and the audit has been initiated, the progression along the EHR Incentive Program timeline has begun and the provider would need to meet MU along this schedule in order to earn the associated incentive payments.
Please see title=https://questions.cms.gov/reps/faq.php?faqId=7737" target=FAQ 7737 for information about the meaningful use progression in the Medicaid EHR Incentive Program.
For more information about the EHR Incentive Program timeline, please visit http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Basics.html To use the interactive “My EHR Participation Timeline” tool, please visit: http://cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Participation-Timeline.html
(FAQ9220)
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