FAQ: How do I qualify for the EHR Incentive Program?

The first step toward participating in the federal EHR Incentive Program is making sure your organization qualifies. Here's what hospitals and eligible providers need to know.

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The federal government's voluntary Electronic Health Record Incentive Program gives cash to hospitals and other eligible professionals (EPs) who successfully demonstrate the meaningful use of EHR technology.

The process isn't easy. Organizations must obtain a certified EHR system, use that system to meet the meaningful use criteria for a continuous, 90-day period in the first year, and submit a report to the Centers for Medicare & Medicaid Services (CMS). In addition, providers must submit reports on either clinical quality measures or hospital quality measures. Then and only then do they get their meaningful use incentive payment -- and those who fail to demonstrate meaningful use by 2015 are subject to financial penalties under the Health Information Technology for Economic and Clinical Health (HITECH) Act.

Health care providers can easily overlook one step, however: ensuring that they actually qualify for the EHR Incentive Program. As with credit card rewards, some restrictions apply. Here are the criteria organizations must meet to be eligible for meaningful use incentives.

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What is the Medicare EHR incentive program for EPs?

Under meaningful use, five types of physicians are considered Medicare eligible professionals: doctors of medicine or osteopathy, doctors of dental surgery or dental medicine, podiatrists, optometrists, and chiropractors. Physicians who perform more than 90% of their services in a hospital inpatient or emergency room setting, however, are not eligible. As CMS sees it, such physicians are predominantly using the hospital's EHR system and do not need to invest in their own system.

Participants must demonstrate at least the first stage of meaningful use by the end of 2012 to qualify for the maximum incentive, which is $44,000. (Those who practice in a federally defined Health Provider Shortage Area can get as much as $48,400.) Under the Stage 1 meaningful use criteria, providers and hospitals are required to meet 15 core requirements and five of 10 "menu" requirements. Criteria for meaningful use beyond Stage 1 will be set in 2011.

A tip sheet from CMS for the Medicare EHR Incentive Program provides additional information.

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What is the Medicaid EHR incentive program for EPs?

The Medicaid program is administered by states and territories, not the federal government. Medicaid eligible professionals include physicians, nurse practitioners, certified nurse-midwives, dentists and physician assistants who provide services in a Federally Qualified Health Center (FQHC) or rural health clinic (RHC).

As with the Medicare EHR Incentive Program, physicians are not eligible who perform more than 90% of their services in a hospital inpatient or emergency room setting. In addition, EPs must meet one of these three criteria:

  • At least 20% of a pediatrician's patients must be insured under Medicaid. Patients insured by the Children's Health Insurance Program (CHIP) are excluded from that percentage.
  • If a doctor is employed in an FQHC or RHC, at least 30% of his work must be with Medicaid patients.
  • All other doctors must work at least 30% of the time with patients who are insured under Medicaid; patients who are insured by CHIP are excluded.

Participants must demonstrate meaningful use by 2016 to receive the maximum payment amount, which is $63,750. Even with that extended deadline, those who do not demonstrate meaningful use by 2015 are subject to penalties.

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Can an EP participate in both the Medicare and Medicaid programs?

Not really. If an EP qualifies for one program before 2015, he may switch between the Medicare and Medicaid programs once -- but only once, and there's no switching back. In doing so, a provider does not start over; rather, he is placed into the payment year he would have been in if he hadn't made the switch. For example, leaving the Medicare program after the second payment year means joining the Medicaid program in the third payment year.

Additional information is available in the EHR Incentive Program flow chart, which the CMS created for EPs.

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Which EHR incentive programs apply to hospitals?

There are three. The EHR Incentive Program for Medicare hospitals applies to three types of facilities: Subsection D hospitals (general, acute care, short-term hospitals paid under the inpatient prospective payment system), critical access hospitals and Medicare Advantage hospitals.

The EHR Incentive Program for Medicaid hospitals applies to acute care hospitals (including critical access hospitals) where at least 10% of the patients are insured under Medicaid, and children's hospitals (which are not required to have a certain percentage of patients insured under Medicaid). Medicaid hospitals that also are Medicare Subsection D hospitals may receive EHR incentive payments from both programs.

Finally, there are special provisions of the EHR Incentive Program for critical access hospitals certified under Section 1820(c) of the Social Security Act. Critical access hospitals where at least 10% of the patients are insured by Medicaid also are eligible for payment from that program.

Certain hospitals are eligible to participate in more than one program if they meet all eligibility criteria, but in no case is a hospital eligible for an EHR incentive payment for more than four years. In addition, health systems are allowed only one payment per Medicare reporting number, regardless of the number of facilities they have.

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Does participating in the EHR incentive program disqualify me from other federal programs?

In some cases, yes. Medicare EPs, for example, cannot participate in the Electronic Prescribing (eRx) Incentive Program; Medicaid EPs, however, still can.

Organizations that have been participating already in other CMS incentive programs -- namely, the Physicians Quality Reporting Initiative (PQRI) and the Hospital Inpatient Quality Reporting Program -- may continue to do so. In fact, many of the clinical quality measures required by meaningful use are based on existing PQRI measures, while nearly all the hospital quality measures in the meaningful use final rule are based on existing measures.

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Let us know what you think about the FAQ; email editor@searchhealthit.com.

This was first published in October 2010

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