We have learned that CMS has paid Medicare EHR Incentive Program Payments to some eligible hospitals using an incorrect transition factor, understating total payment. CMS personnel have informed us that they are aware of this problem and that the agency intends to implement a system edit that will pay the remaining balance using the correct transition factor no later than the end of October 2014. The statutory formula by which CMS pays out Medicare EHR Incentive Payments includes a transition factor that reduces the total payment with each year an eligible provider participates in the Program. Eligible providers that have successfully attested to Meaningful Use should verify that their payments have been made using the correct transition factor. Those providers paid using an incorrect transition factor should monitor their pay-to account and verify that CMS has paid the remaining balance by the end of October.

Reporter(s), Christopher Kenny, Washington, D.C., + 1 202 626 9253, ckenny@kslaw.com.