So who do you trust on these tricky legal issues? The cynical aviation doc (David, sometime I would like to hear more about what you do. Are there really enough plane crashes up there to make a living treating the survivors? Or do you treat healthy people, but only when they are on planes?), the even more cynical GI doc, the thoughtful and mathematically inclined pediatricians, or the tech guy? Bill, I think you need to get a lawyer. Of course, when the bill is paid, that will leave you about $2 of the 18k.....
I guess this could be kind of sticky. I think that CMS determines how many docs can apply for the MU incentive based on distinct PECOS numbers; you can't get the $ without a number. (This is different from your tax ID). The money is then paid to that provider; OR if they have assigned all of their Medicare earnings to another entity, then the money is paid there. Bill, I assume that all of your subcontractors billings are paid to your corp/LLC, etc. If not, you may have a problem. So she is eligible for the money, but you will request it (just as you bill for her E and M codes). You will then keep it and pay her by the hour (just as you keep the E and M money and pay her hourly).
Also, one thing that Jon B. regularly points out (unlike others who are less honest) is that not everyone is entitled to $18k. You can get 75% of your Medicare collections up to that amount. So unless your employee brings in more than $24k of Medicare collections a year, the amount will be less than 18k.
