Meaningful Use Payments Arrive

HITECH Incentive payments began on May 19, four weeks after attestation for Meaningful Use became available. 

On May 19, BIDMC received the following electronic funds transfer from CMS/Medicare:

CORPORATE TRADE PAYMENT CREDIT
CMS (EHR INCENT) DES:HITECH PMT ID:

BIDMC was the first hospital in the country to attest to meaningful use and received payment from CMS on the first day of stimulus disbursements.   Hospital payments start with a $2 million base payment.  Per the CMS FAQ 

"Eligible hospitals and CAHs will receive an initial payment and a final payment. Eligible hospitals and Critical Access Hospitals that attest in April can receive their initial payment as early as May 2011. Final payment will be determined at the time of settling the hospital cost report."

Although we received an initial $2 million dollar payment, we have not received information about the final payment calculation or timing.

Some have worried that attesting early will create a timeline for stage 2 that is challenging to meet i.e.

Standards Committee work for stage 2 will be done by September 2011
ONC proposed regulations will be drafted in the Fall, released in December and will become final in mid 2012
The Stage 2 meaningful use demonstration period begins October 1, 2012

The likelihood that regulations can be transformed into working, implemented software by October 1, 2012 is slim.

Hence the HIT Policy Committee will likely recommend that Meaningful Use Stage 2 be deferred a year, meaning that the demonstration period for those who attest to stage 1 in 2011 will be moved to October 1, 2013.

Based on everything I know, here's the workplan I'd recommend for IT departments
1.  In 2011, update your purchased products as needed to implement meaningful use versions
2.  In 2011, if your systems are built rather than bought (or are a combination of the two), use the CCHIT EACH program to certify your site as needed for hospital and ambulatory certification criteria.
3.  In 2011, educate your clinicians and measure meaningful use metrics for a 90 day demonstration period.  Note that this can be done in parallel with certification, since systems only need to be certified by the end of the demonstration period
4.  In 2011, collect your initial meaningful use payments
5.  In 2011, work on X12 5010 for the January 1, 2012 deadline
6.  In 2011, begin ICD10 planning for the October 1, 2013 deadline.   I believe this deadline will be extended.
7.  In 2012,  plan on beginning your Meaningful Use stage 2 measurement period on October 1, 2013.

A lot going on in parallel, but by taking it one day at time, step by step, it's doable.