Qualifying physicians are eligible for incentives equaling 75 percent of their allowed Medicare Part B charges for covered professional services, subject to the maximum allowable. The total physicians ultimately receive will vary based on start date, as seen in the chart below. Physicians who began participating in 2011 or 2012 can receive up to $44,000. The amount decreases for each succeeding year. Additionally, penalties will be assessed beginning in 2015 based on successful participation in preceding years. Given this, the ACC strongly encourages you to assess your readiness to participate quickly because the review of the requirements and workflow changes can take time.

CY Begin Participation

Calendar Year for Which Payment Is Made

2011

2012

2013

2014

2015

2016

Total

2011

$18,000

$12,000

$8,000

$4,000

$2,000

$44,000

2012

$18,000

$12,000

$8,000

$4,000

$2,000

$44,000

2013

$15,000

$12,000

$8,000

$4,000

$39,000

2014

$12,000

$8,000

$4,000

$24,000

2015+

-1% of PFS penalty

-2% of PFS penalty

$0

Payment process

CMS makes payments on a rolling basis to those with evidence of successful completion of the requirements. Since the reporting period of a participant’s first year is 90 days and the incentive payment is based on a percentage of allowable charges, CMS will withhold those payments until participants reach the maximum allowable. (The Agency does not anticipate that individual practitioners will have submitted enough claims to reach the maximum allowable by the end of those 90 days.) Payments will be made to a single Tax Identification Number and will be issued based on the physician’s National Provider Identifier. If a physician has a valid contractual arrangement allowing his or her employer to bill for his or her services and has executed a reassignment (CMS-855R), the incentive payment will be made to the employer. There are no special requirements or restrictions regarding the distribution of these funds. However, participants should be aware that an exception to the physician self-referral (Stark) rule and a safe harbor to the anti-kickback statute have been added to specifically address questions relating to EHRs. These exceptions and safe harbors are due to sunset at the end of 2021. You should consult an attorney regarding any questions on these two provisions.

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