Academic medical centers, integrated entities, hospitals that employ physicians and medical groups may not be taking the needed steps to secure payment of physician “meaningful use” incentives from Medicare and Medicaid.

At risk are relationships with participating physicians, as well as the potentially significant payment streams.

Why at Risk?

  • Academic medical centers, integrated entities, and employers will not receive the physician incentive payments automatically.
  • The general assignment of Medicare payments does not assign the physician MU payments.
  • Only physicians may register and apply – and they must do so personally.
  • The application process is complex – physicians must verify EHR use and elect between Medicare and Medicaid. Without guidance, many will not apply or will do so incorrectly.
  • The attestation process for Medicare begins in April 2011.  

The Stakes

  • Medicare – up to $44,000 per physician (over 5 yrs.)
  • Medicaid – up to $63,750 per physician (over 6 yrs.)
  • For example, an AMC or a health system with 150 eligible physicians may expect to receive physician MU payments up to $6.6 million.

Whose Money Is It?

  • Physician MU incentive payments are paid to individual physicians.
  • These payments can only go to the organization which employs them if physicians correctly make a specific assignment to it.

Three Elements

There are three elements to understand and coordinate:

  • CMS rules and registration;
  • State law on assignment of payment rights; and
  • “Stark” and antikickback regulation.

Coordination

Organizations that include physicians who may be eligible for the federal MU incentive payments should:

  • Understand how the CMS process works;
  • Determine how physician MU incentive funds will be allocated (to the physicians, to the organization, or shared);
  • Assess the legal and regulatory issues;
  • Educate their physicians; and
  • Carefully coordinate the registration and attestation process.