Sound impossible? Well, there is one small loophole. First, you have to qualify as a Medicaid Provider. Second, you have to be in the process of adopting, implementing or upgrading your EHR. (Page 317 of the Proposed Rule, among other references) Of course, there are some further stipulations. If you are a hospital, your Medicaid patient volume must be at least 10%; Children's Hospitals are exempt from this minimum. Of course, this reimbursement is on the Medicaid side. For Medicare all providers must first demonstrate meaningful use before getting any money.
Remember how each years' reimbursement are not of equal amounts, and are front-loaded with dollar amounts that decline each year? Ok ... let's say you decided to go for Medicaid reimbursement in 2011 under this idea. You are in process of implementing your EMR, but not yet at Meaningful Use status. Fine! You qualify and get your money. Now, let's assume bad news. Your implementation project slipped and you are not ready to qualify in 2012, and slip to 2013 as your first Meaningful Use year. Sadly, you know that you get no money in 2012. But the question open to further research is this ... will 2013 be treated as your second payment year, or your third?????
The good news, is that Medicaid does not penalize hospitals for starting late. Medicaid incentives are paid out starting as late as 2016 (if you start after 2016 you don't get any incentives), and once you've started, you continue to receive the full amount.
Oh, yeah ... the "earlier" part. Well, under Medicare providers can't have a "first payment year" until 2011 (Fiscal for hospitals, Calendar for EP's). But ... if your State applies with CMS, and is approved, you may be able to get "first payment year" in 2010. So keep an eye on your State Medicaid Agency, if you think you might be able to qualify early. They just might be able to funnel some cash your way a year early. Good Luck!
Jay Fisher | @JayRFisher
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