Under ARRA, hospitals are eligible for Medicaid or Medicare incentive payments in 2011 and subject to penalties in 2015.

Medicare will provide incentive payments in federal fiscal years 2011 through 2016. Medicare penalties for failing to meet meaningful use requirements will begin in 2015 and be phased in through 2017, at which point they are permanent.

Medicaid incentive payments will commence at the discretion of each state, but must begin by 2016 and may not extend past 2021; no hospital can receive Medicaid incentive payments for longer than six years.

To download the timeline above, go to:
https://www.cms.gov/EHRIncentivePrograms/Downloads/EHRIncentProgtimeline508V1.pdf

The EHR implementation process is lengthy and complicated and can last multiple years. Further, the implementation will overlap with other key IT initiatives such as Transition to ICD-10, Administrative Simplification, HIPAA Privacy changes, and health care reform changes. The AHA created a map of these overlapping efforts and timelines to help both hospitals and policymakers understand the interactions among these new programs and initiatives. The AHA is particularly concerned that, under current timelines, Stage 2 of meaningful use is scheduled to begin under ICD-9 (in October 12), but than transition to ICD-10 in its second year (in October 2013). We have advocated that Stage 2 start only when 75 percent of hospitals and physicians have met the Stage 1 requirements and no sooner than Fiscal Year 2013.

To download "Overlapping Timelines of ICD-10, Meaningful Use of EHRs, and Health Reform Initiatives," click the image above.