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Coordinating a Practice in Different Stages

Eligible professionals (EPs) attest to the program and earn incentive payments as individuals, but coordination within a practice or group is often required on various aspects of the program. This coordination is complicated when EPs in the same practice are in different stages of the program. The ability to achieve meaningful use is not limited by other EPs’ efforts: six EPs in the same group could be participating following six different timelines. Identifying the progression for each EP or group of EPs through the stages of meaningful use and their various reporting periods is the first step; the second step is coordinating whether the Medicaid patient volume data, always calculated for 90 days in the year preceding the year of adopting, implementing, or upgrading (AIU) or meaningful use activities, will be calculated for the group or for each individual.  The selection one year does not limit the options the following year, but each EP in the group must use either an individual or group patient volume calculation within each year.

Eligible Professionals Joining a Practice
EPs can join a practice and begin participating in the EHR Incentive Program anytime through 2016. Eligible professionals in a practice can be participating in different stages of the program and still attest to group patient volume data and/or pay the group their incentive payments, or may opt to submit individual patient volume data and/or receive individual payments. The new providers’ patient volumes can be added to the total patient volume in order to calculate an accurate patient volume for the practice even if they begin participating in a different year than their counterparts. The group attests to patient volume data as a whole, or they each attest individually. For example, two providers cannot join a group of three providers with three attesting to group patient volume and two attesting individually.

An example: Practice A had 15 EPs in 2010. Each attested to AIU in 2011 (Payment Year 1) based on 2010 patient volume averaged over the group. In 2011, the practice hired five providers. None of these five providers had participated in the EHR Incentive Program in their previous positions.

To participate in the program, the five providers will register and attest to AIU in 2012 based on 2011 patient volume data calculated across the group of 20. These five EPs will be in Payment Year 1 in 2012, while their colleagues are in Payment Year 2. These EPs can attest to AIU beginning in January of the payment year, 2012, and could attest to AIU for 2012as late as March 31, 2013.

To earn an incentive in their Payment Year 2 (2012), the 15 original providers are going to attest to patient volume calculated for 90 consecutive days in 2011 as well as attest to meaningful use measures for 90 consecutive days in 2012. To attest to patient volume as a group of 20, these EPs will use the same 2011 patient volume data as their new colleagues.

In 2013, five EPs will be in Payment Year 2, while 15 will be in Payment Year 3. The five EPs can attest to meaningful use as soon as they achieve the meaningful use objectives in 90 consecutive days, while the 15 are required to have a full calendar year of meaningful use, so they cannot attest until 2014 for 2013 meaningful use. The practice will have to handle generating individual provider meaningful use reports for two reporting periods but only one set of patient volume data.

Each subset of providers will have the potential to earn the full six years of incentive payments.

Eligible Professionals Transferring Practices
EPs can transfer their practice location(s) at any time during the program. As EPs attest and earn incentive payments as individuals, these EPs would maintain their progression in the program. If they completed Stage 1 for 90 days at their previous practice, they would move on to complete Stage 1 for 365 days at their new practice. They may consider skipping a year before pursuing this meaningful use giving the timing of the transfer or the training required on a different certified product. The option to attest in non-consecutive years is always an option when selecting the appropriate timeline to progress through the stages of meaningful use. Transferring providers cannot return to a previously completed stage or earn more than six years of incentive payments, however, regardless of to whom their incentive payment was assigned or who purchased the certified EHR technology. Each individual will follow his individual timeline throughout the program, coordinating his patient volume calculation with his group as appropriate.

These transfers may result in similar challenges in practices as when new providers join. The option to choose a group or individual patient volume calculation is a group-wide choice not limited by any EP’s choice in a previous year. Additionally, updating the EP information on the CMS Registration and Attestation website would be required rather than initially registering through that site.