Incentives and Penalties for Promoting Interoperability

Medicaid Promoting Interoperability Incentives & Penalties

Incentive payments for Medicaid clinicians are spread out over time. Unlike Medicare where clinicians had to start in 2011 to receive the maximum incentive, Medicaid clinicians qualified for the Meaningful Use program in the 2016 performance year and still receive payouts through 2021, totaling the full incentive amount of $63,750.

Penalties were assessed for dual-eligible Medicaid/Medicare providers who didn't transition to Meaningful Use starting in 2015. The penalty increased over time from one percent in 2015 to two percent in 2016, and three percent in 2017. While that may seem like a small amount, it added up to a significant fee for hospitals and other providers if they decided they were not going to comply.

The best way to avoid penalties and maximize financial benefit was to start immediately and ensure compliance every year through 2021. 

Payments are staggered depending on when organizations began to participate. Below is the CMS schedule through 2021:

 Medicaid EP Qualifies to Receive First Payment in 2011Medicaid EP Qualifies to Receive First Payment in 2012Medicaid EP Qualifies to Receive First Payment in 2013Medicaid EP Qualifies to Receive First Payment in 2014Medicaid EP Qualifies to Receive First Payment in 2015Medicaid EP Qualifies to Receive First Payment in 2016
Payment Amount in 2011$21,250$0.00$0.00$0.00$0.00$0.00
Payment Amount in 2012$8,500$21,250$0.00$0.00$0.00$0.00
Payment Amount in 2013$8,500$8,500$21,250$0.00$0.00$0.00
Payment Amount in 2014$8,500$8,500$8,500$21,250$0.00$0.00
Payment Amount in 2015$8,500$8,500$8,500$8,500$21,250$0.00
Payment Amount in 2016$8,500$8,500$8,500$8,500$8,500$21,250
Payment Amount in 2017$0.00$8,500$8,500$8,500$8,500$8,500
Payment Amount in 2018$0.00$0.00$8,500$8,500$8,500$8,500
Payment Amount in 2019$0.00$0.00$0.00$8,500$8,500$8,500
Payment Amount in 2020$0.00$0.00$0.00$0.00$8,500$8,500
Payment Amount in 2021$0.00$0.00$0.00$0.00$0.00$8,500
Total Incentive Payments$63,750$63,750$63,750$63,750$63,750$63,750

 

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