In yesterday’s post we reviewed when “Payment Years” began with respect to the ARRA. Today, we’ll review the other key component of ARRA timing–”Reporting Periods”.

For “Eligible Professionals” a Reporting Period is:

For the FIRST Payment Year:

• Any continuous 90-day period within a calendar year.

For the second, third and fourth payment years:

• The calendar year.

For Eligible Hospitals (or critical access hospitals):

For the FIRST Payment Year:

• Any continuous 90-day period within the FEDERAL fiscal year (October 1 – September 30).

For the second, third and fourth payment years:

• The Federal fiscal year (i.e. beginning Oct 1)

There’s a bit of confusion (understandably so) regarding the specific dates associated with the ARRA funding, and the “Meaningful Use” requirements.

Unfortunately, the answer to the question “When do I need to be up and running with my EMR?” has a number of possibilities depending on your status:

For “Eligible Professionals”:

Filing for MEDICARE:

• A “Payment Year” is a calendar year starting in 2011.

Filing for MEDICAID:

• A “Payment Year” begins in 2010 for adoption, implementation or upgrading of a certified EHR.

• Meaningful Use begins in 2011.

REMEMBER – you can file for EITHER Medicare OR Medicaid, but NOT BOTH!

For Eligible Hospitals (or critical access hospitals):

“Payment Year” is based on the FEDERAL FISCAL YEAR (which is October 1 through September 30).

• A Payment Year begins in Fiscal Year (FY) 2011 (i.e. October 1, 2010)