EHR Incentive Program marches on

June 27, 2017

Article

Having assisted dental groups and DSOs obtain EHR subsidy payments over these past few years, I can tell you that because of all the misinformation and misunderstanding about the rules behind this program, many groups and DSOs will miss out on millions of additional payments over the next five years if they don’t truly understand what their ongoing rights are.

With this article I will try to attempt to clarify which aspects of the subsidy program are closed and how groups and DSOs can still take advantage of the part of the program that allows for continuing payments.

To understand what you can and can’t do moving forward, let’s do a quick review of the subsidy program itself. I was part of a growing effort about seven years ago to try to make next-generation EHR technology affordable in health care. In 2011, we implemented a system of subsidies drawn from Medicare and Medicaid based on a willingness to integrate best practices electronic health records. Most of the Medicare-based payments from this program were centered in the medical world.

However, the Medicaid-based part of this program was very much in play for many dental groups and DSOs. If eligible, a group, DSO or practice could receive over $63,000 in subsidy payments over a six-year period

The nuances of Year One eligibility

The first step to becoming part of the program was to register and apply for Year One incentive money.

The misconception in the industry was that if you did not actually apply and attest for subsidies by the end of 2016, then you couldn’t enter the program at all. However, if you had purchased certified dental software by the end of 2016 (whether locally installed or a cloud-based model) and had at least one provider who previously saw 30 percent or more Medicaid patients, then you had-and continue to have, in some cases-well into 2017 to actually apply for your Year One money, as many of the states have extended their deadlines.

Case in point: Late last year I had a discussion with a large DSO that thought it was too late to get a number of their providers registered for the program because they had heard that they had to get all paperwork in by the end of 2016. In reality, their state extended the applications and attestations for almost five months. That gave us time to submit paperwork for a number of their providers, and I helped them to potentially receive over $500,000 in subsidies this year alone. Nevada has extended their deadlines until the fall, and Colorado hasn’t even started their attestation yet.

If you are eligible, it is worthwhile to look at where your individual state is on this. At the end of the day, it is true that this year was the last year to enter the program and be eligible for an additional five years of subsidies. But, as pointed out, 2017 proved to have several state deadline extensions and grace periods to allow groups, DSOs and practices to complete the work and be part of this program that runs through 2021.

Don’t quit now: Five more years to go

The number of groups and DSOs that have contacted me after reading my articles or viewing my webinars to say they didn’t even realize this was a six-year program has been eye-opening.

Many of them thought that after they received their Year One payment of $21,250 per provider that this was the end of it. However, a group or DSO that is still eligible can obtain $8,500 per provider per year over the next five years if they show that they are using certified software technology. In the case of one DSO I’m working with, because of the number of providers, they have the potential to get over $750,000 per year in subsidies through 2021. The unfortunate part is that many times groups don’t even know that they have eligible providers that they could apply for.

For example, I’m working with a group that had hired several new dentists over the past few years. After I checked with CMS, we found out that many of them had previously registered for Year One subsidies while working for different groups. So, they were already in the program and eligible to receive additional money. This is important to understand: Over the next five years, a group or DSO can receive subsidies for providers who have registered and attested while working at that particular group or DSO, as well as any newly employed provider who received Year One money while part of a different group. Another key point is that many times a provider is not even aware that a previous group had registered them for Year One subsidies. So, it is worthwhile for a group or DSO to check your providers through CMS and see if they were previously registered for the program with another organization.

Certified dental software vendors gaining customers

The good news for software vendors that have invested time and effort into becoming certified is that because there is a lot of subsidy money remaining for five more years, they have the opportunity to “flip” organizations from outdated software to newer certified software models.

I have pointed this out to several software vendors based on my experience. Think about it: If you were a group or DSO and could obtain a few hundred thousand dollars per year in subsidies for the next five years if you had certified software, wouldn’t it be worth it to at least consider switching software? Besides, group and DSO software is changing dramatically anyway. So, if the medical market, which has evolved to a large percentage of certified vendors, is any indication of where the dental software market is going, these vendors should be very happy.