Frequently Asked Questions

Click on a link below for answers to commonly asked questions. Please note the reference links throughout the information for their original sources. All individuals and institutions should review the American Recovery and Reinvestment Act of 2009 directly or seek advice of counsel. Contact LSS if you have specific questions.

General Questions
What are the incentive program time frames?
What qualifies a user as a "meaningful EHR user"?
What are the Stage 1 Eligible Professional (EP) Meaningful Use Objectives and Measures?
How will the measure data be submitted to CMS?
Can an eligible professional qualify for multiple incentive programs through the ARRA?
How are hospital-based eligible professionals defined?
Does a group practice qualify as a whole, or does each eligible professional (EP) qualify individually?
How will the new certification process work?
What is the Federal Healthcare Information Technology Standards Committee?
What is the Federal Health Information Technology Policy Committee?
In addition to being on a certified Meaningful Use release, do I need to purchase additional software from LSS to meet Meaningful Use Stage 1?
HHS announced (on 11/30/11) that it intends to delay Stage 2 by one year, what does this mean for Eligible Providers?

Medicare Incentive Program
When will Medicare incentive payments begin?
Who is an eligible professional?
What are covered professional services?
How much are the incentives for Eligible Professionals (EPs)?
What are the penalties associated with not using a certified EHR technology in a meaningful way?
What's a Medicare incentive payment example?
What's a Medicare payment adjustment example?

Medicaid Incentive Program
When will Medicaid incentive payments begin?
Who is an eligible professional?
What are the average allowable costs for the Medicaid incentive?
If an eligible professional qualifies for both the Medicare and Medicaid programs and selects Medicaid, but doesn’t begin implementing until 2016 are they subject to the penalties under the Medicare program?
How are needy individuals defined?
How is "meaningful use" defined for the Medicaid Program?
How is an electronic health record identified as a certified EHR?
How much are the incentives?

What are the incentive program time frames?

What qualifies a user as a "meaningful EHR user"?
There are three main requirements an eligible professional (EP) needs to meet to be identified as a meaningful EHR user. The first is that the eligible professional demonstrates, to the satisfaction of the Secretary of Health and Human Services, that they are using a certified EHR in a meaningful manner, which shall include the use of electronic prescribing as determined by the Secretary.

The Office of the National Coordinator (ONC) issued a temporary certification program final rule June 2010 that outlines the process for selecting organizations to certify EHR technology. The selected organizations will use the standards, certification criteria, and the National Institute for Standards and Technology (NIST) test procedures to certify EHR technology. To date no certification organizations have been selected and no products certified. To demonstrate this requirement the EP will need to report the use of a certified EHR and identifying the specific technology used.

The second requirement is that the professional can demonstrate that the certified EHR technology is connected in a manner that provides for the electronic exchange of health information to improve the quality of health care such as promoting care coordination. The demonstration of these two requirements may require the professional to provide:

• an attestation
• the submission of claims with appropriate coding (such as a code indicating that a patient encounter was documented by using a certified EHR technology)
• a survey response
• and any other measures specified by the Secretary

CMS published on July 28, 2010, a final regulation in the Federal Register which includes further clarification on the objectives of meaningful use and how EPs will comply to receive incentives. CMS's meaningful use definition is based on five broad health outcomes:

1. Improve quality, safety, efficiency, and reduce health disparities
2. Engage patients and families
3. Improve care coordination
4. Improve population and public health
5. Ensure adequate privacy and security protections for personal health information

Using these broad health outcomes, CMS has identified 15 core objectives and 10 menu set objectives. For a provider to qualify for meaningful use they must report the measures or exclusions for each of the 15 core objectives and at least 5 of the 10 menu set objectives. If an EP is ineligible for one of the 10 menu set objectives then they will need to attest to that exclusion and only report on 4 of the remaining 9 menu set objectives.

The final requirement is that the professional report any quality measures selected by the Secretary, with a focus on clinical quality measures. All measures shall be published in the Federal Register, prior to the Secretary's selection, for public comment.

One of the 15 core objectives included in the Meaningful Use Final Rule is to report on clinical quality measures. EPs must report from the table of 44 clinical quality measures which includes 3 Core, 3 Alternate Core, and 38 additional clinical quality measures. EPs must report on the 3 core measures unless the denominator of one or more of the core measures is 0, then the EPs are required to report results for up to 3 of the alternate core measures. EPs are also required to select 3 of the remaining 38 quality measures to report.

In each of these categories CMS has identified meaningful use objectives and measures for a total of 25 that each EP will have to meet. One of those objectives is reporting on clinical quality measures, which are also outlined in the rule. CMS has identified 90 possible clinical quality measures, of which each EP will report on a subset of the those measures, a core set and measures based on the EP's specialty.

CFR 42 § 495.6 (a) Page 255
CFR 42 § 495.8 (a) Pages 258 – 259
Section II.A.2 (Pages 9 – 68) of the CMS Final Rule
Division B, Title IV, Subtitle A, Sec 4101(a2)

What are the Stage 1 Eligible Professional (EP) Meaningful Use Objectives and Measures?
The following chart outlines all of the Stage 1 Meaningful Use Objectives and Measures for EPs. The column to the right identifies the reporting structure for the measures in 2011 (Y/N – Yes or no submitted through attestation; N/D – A numerator and denominator are submitted for each measure through attestation).

CFR 42 § 495.6 (c) Page 255 – 258
Section II.A.2.c (Pages 14 - 68) of the CMS NPRM

How will the measure data be submitted to CMS?
All meaningful use measures and clinical quality measures will be submitted through a one-time attestation in 2011 after the end of the reporting period. The EP will attest through a secure mechanism in a manner specified by CMS (or for a Medicaid EP, in a manner specified by the State). In 2012 all the meaningful use measures except for clinical quality measures will be reported through a one-time attestation at the end of the reporting period. The clinical quality measures in 2012 will at least be partially submitted electronically to CMS (or for a Medicaid EP, the State).

As EHR technology and meaningful use progress, CMS is expecting to change the reporting requirements to include more direct electronic data submission. More details are expected regarding the process of submitting this data electronically to CMS on or before July 1, 2011 for eligible professionals.

CFR 42 § 495.8(a), Pages 258 - 259
Section II.A.4.b (Pages 124 - 125) of the CMS Final Rule

Can an eligible professional qualify for multiple incentive programs through the ARRA?
An eligible professional (EP) may be qualified for multiple programs through the ARRA, but they are only able to receive incentive dollars through one of the programs and must notify CMS of their preference. This makes it important for an EP to analyze their current patient encounters and eligible charges to select the appropriate program for their practice. EPs can switch between the two programs just once and only after receiving at least one incentive payment. The switch also needs to be completed prior to the 2015 payment year and the EP is limited to receiving, in total, the maximum payments under the Medicaid EHR program ($63,750).

If an EP elects to switch programs, CMS will transition the EP to the new program on the same year of eligibility as their previous program. For example, if you receive two years of incentives through the Medicare program, you would transition to the Medicaid program starting on your third year of eligibility.

CFR 42 § 495.10(e), Page 260
Section II.A.5 (Pages 125 - 127) of the CMS Final Rule

How are hospital-based eligible professionals defined?
The ARRA defines hospital-based provider as:

"…an EP (as defined under this section) who furnishes 90 percent or more of his or her covered professional services in a hospital setting in the year preceding the payment year. For Medicare, this will be calculated based on the Federal FY prior to the payment year. For Medicaid, it is at the State’s discretion if the data is gathered on the Federal FY or CY prior to the payment year. A setting is considered a hospital setting if it is a site of service that would be identified by the codes used in the HIPAA standard transactions as an inpatient hospital, or emergency room setting."

There is one exception to this rule. Medicaid EPs practicing in Rural Health Clinics and Federally Qualified Health Centers are exempt from the hospital-based exclusion.

CFR 42 § 495.4(Hospital-based EP), Page 254
Section II.A.6 (Pages 127 – 130) of the CMS Final Rule

Does a group practice qualify as a whole, or does each eligible professional (EP) qualify individually?
The incentive programs are designed to be implemented on an individual provider basis. For example, in a group practice with 8 providers, each provider has the ability to participate in either program (Medicare or Medicaid) for which they are eligible. Individual physicians within the practice do not have to qualify in the same year, meaning that if one qualifies in 2011 and the rest do not until 2012, those qualifying in 2012 will not loose a year of eligibility.

An individual EP's incentive payment can be reassigned to their employer or to an entity with which they have a contractual arrangement which allows that organization to bill and receive payment for the EP's covered professional services. If the EP elects to do this, the entire payment is reassigned to only one employer or entity.

The Medicare Advantage program, on the other hand, requires that all providers within the Medicare Advantage Organization qualify in the same year. This means that if the Medicare Advantage Organization applies and qualifies in 2011 they receive only the incentives for those EPs within it that met meaningful use during the reporting period and any EPs who didn’t would not receive an incentive for their first payment year.

CFR 42 § 495.10(f), Page 260
CFR 42 § 495 Subpart C, Pages 263 - 265

How will the new certification process work?
To qualify for the incentive payments eligible professionals and health care organizations are required to implement a certified EHR technology. Currently the only Federally recognized certification body is the Certification Commission for Health Information Technology (CCHIT), but the ARRA redefines certification criteria and standards and creates a new certification processes.

The new process gives the power to the National Coordinator, in consultation with the Director of the National Institute of Standards and Technology, to recognize a certification program or programs to qualify EHR technology. The Office of the National Coordinator (ONC) has decided to replace their current certification recognition program and has proposed both a new temporary and permanent certification program, to meet the deadlines laid out in the ARRA.

The temporary program was finalized on June 24, 2010, through a regulation published in the Federal Register. This rule outlines the selection process for the newly created Authorized Testing and Certification Bodies (ONC-ATCB). ONC has begun the selection processes and will be identifying the first ONC-ATCBs in late summer of 2010. The temporary certification program will expire on December 31, 2012 and will be replaced by the permanent program.

The law also creates a process for identifying new certification criteria through the Department of Health and Humans Services and the ONC. On July 28, 2010 the ONC published in the Federal Register a Final Rule outlining the new certification criteria, standards, and implementation specifications.

Temporary Certification Final Rule
Division B, Title IV, Subtitle A, Sec 4101(a4)
Division A, Title XIII, Subtitle A, Sec 3001(c5)

What is the Federal Healthcare Information Technology Standards Committee?
The HIT Standards Committee was created as Federal Advisory Committee to make recommendations to the National Coordinator on standards, implementation specifications, and certification criteria for the electronic exchange and use of health information. The committee must also work with the HIT Policy Committee to develop, harmonize, and test recognized standards.

The HIT Standards Committee is comprised of providers, ancillary healthcare workers, consumers, purchasers, health plans, technology vendors, researchers, relevant Federal agencies, and individuals with technical expertise on health care quality, privacy and security, and on the electronic exchange and use of health information. The committee held their first meeting May 15, 2009 and has developed a monthly meeting schedule. For more information about the committee and their meetings please visit their website.

Division A, Title XIII, Section 3003

What is the Federal Health Information Technology Policy Committee?
The HIT Policy Committee was created as a Federal Advisory Committee to make recommendations to the National Coordinator relating to the implementation of a nationwide health information technology infrastructure, including implementation of the national HIT strategic plan. Their duties also include identifying areas where the HIT Standards Committee should be creating and defining standards, implementation specifications, and certification criteria.

The committee is comprised of thirteen members representing different areas of the health sector, three appointed by the DHHS Secretary and four political appointees, for a total of 20 members. The HIT Policy Committee convened on May 11, 2009 and has been meeting monthly since. For more information about the committee and their meetings please visit their website.

Division A, Title XIII, Section 3002

In addition to being on a certified Meaningful Use release, do I need to purchase additional software from LSS to meet Meaningful Use Stage 1?
ONC requires that eligible providers possess the functionality required to meet all meaningful use requirements. Therefore, in addition to being on a certified release, customers must also possess the immunization and syndromic surveillance public health interfaces, as well as the Patient Portal. The exact Meaningful Use objectives are as follows:

Syndromic Surveillance - Performed at least one test of certified EHR technology's capacity to provide electronic syndromic surveillance data to public health agencies and follow-up submission if the test is successful (unless none of the public health agencies to which an eligible professional submits such information have the capacity to receive the information electronically).

Immunization Reporting - Performed at least one test of certified EHR technology's capacity to submit electronic data to immunization registries and follow up submission if the test is successful (unless none of the immunization registries to which the eligible professional submits such information have the capacity to receive the information electronically).

Timely Access - More than 10% of all unique patients seen by the EP are provided timely (available to the patient within four business days of being updated in the certified EHR technology) electronic access to their health information subject to the EP's discretion to withhold certain information.

For Meaningful Use Stage 1, eligible professionals are required to test at least one of the two public health measures (Syndromic Surveillance or Immunization Reporting) and have the option to select Timely Access as one of their five menu set items. However, regardless of which requirements the eligible professional selects, they must own both of the public health interfaces and the Patient Portal to meet the requirement of possessing a certified EHR.

Although LSS can leverage some of the same components of the MEDITECH Public Health Interface Suite, a separate eligible professional public health interface package is required. Please contact your LSS sales associate for a formal quote for the eligible provider public health interface package and Patient Portal.

For more information on possession requirements as defined by the ONC, please reference the following FAQs:

FAQ 17: http://healthit.hhs.gov/portal/server.pt?open=512&mode=2&objID=3163&PageID=20779
FAQ 21: http://healthit.hhs.gov/portal/server.pt/community/onc_regulations_faqs/3163/faq_21/21597

HHS announced (on 11/30/11) that it intends to delay Stage 2 by one year, what does this mean for Eligible Providers?
In an effort to make it easier for health care providers and hospitals to qualify for meaningful use incentive payments, HHS has announced major policy changes. Under current regulations, eligible health care providers that attest to Stage 1 of the Medicare EHR incentive program in 2011 would need to meet Stage 2 requirements in 2013. However, HHS has announced that health care providers who attest to Stage 1 in 2011 would not need to meet Stage 2 requirements until 2014, but would still be eligible for the same total incentive payment amount.
http://www.ihealthbeat.org/articles/2011/11/30/sebelius-announces-changes-to-timeline-for-meaningful-use.aspx#ixzz1fIjKNr70

The first year of Stage 1 is a 90 day reporting period, with subsequent years requiring a full year of reporting. The below timeline illustrates the Eligible Provider progression through the stages of meaningful use based on what we know as of 12/06/11 and including the recent HHS announcement.

*Note: Eligible Hospital reporting years are based on federal fiscal year rather than the calendar year. The above chart only has a few of the Eligible Hospital dates displayed.

When will Medicare incentive payments begin?
Medicare incentive payments can begin as early as 90 days after the start of incentive program on January 1, 2011 for eligible professionals (EPs). To be eligible for the maximum incentive dollars an EP will need to begin demonstrating meaningful use sometime before October 1, 2012.

CFR 42 § 495.4 (EHR reporting period), Page 254
Section II.B.1.d (Pages 133-135) of the CMS Final Rule

Who is an eligible professional?
The stimulus act defines an eligible professional using the definition from Section 1861(r) of the Social Security Act. An eligible professional is:

1. a doctor of medicine or osteopathy
2. a doctor of dental surgery or dental medicine
3. a doctor of podiatric medicine
4. a doctor of optometry
5. a chiropractor

All of which must be legally authorized to practice medicine, surgery, or other care by the state in which they perform such functions or actions.

The CMS Final Rule defines hospital-based professionals to be those professionals providing greater than 90% of their covered services from a hospital or emergency department place of service.

CFR 42 § 495.100 (Eligible Professional), Page 260

What are covered professional services?
Covered professional services, are defined as any service for which payment is made under, or is based on, the Physician Fee Schedule (PFS) published each year by the Centers for Medicare & Medicaid Services.

CFR 42 § 495.100 (Covered professional services), Page 260

How much are the incentives for Eligible Professionals (EPs)?
The Medicare Fee-for Service program is designed to offer both a carrot & a stick. The programs include both incentive payments for meaningful use and also payment reductions to reimbursed professional services for EPs and eligible hospitals.

For EPs the incentives and adjustments are based on when a professional becomes a "meaningful user" of a certified EHR technology. If the EP becomes a meaningful user before 2014 they are eligible for incentive payments. If the EP doesn't become a meaningful user by 2015 they may be subject to an adjustment in their covered professional services through Medicare.

The payment schedule below illustrates the standard incentive schedule for Medicare EPs. The incentive payments are paid out over three to five payment years. In the first payment year the EP is eligible for up to $15,000, unless the first payment year is either 2011 or 2012, where the EP is eligible for $18,000. This is in an effort to reward early adopters of certified EHR technologies. The subsequent four payments years work as follows:*

• Second payment year – $12,000
• Third payment year – $8,000
• Fourth payment year – $4,000
• Fifth payment year – $2,000

If the EP's first payment year is after 2013 then the initial payment decreases to the second year payment of $12,000. The incentives are also limited so that any EP who adopts after 2014 will not be eligible for an incentive program. The ARRA also specifies that no incentive payments will be paid out after 2016.

CFR 42 § 495.102(b), Page 260
Section II.B.1.b (Pages 131 - 132) of the CMS Final Rule
Division B, Title IV, Subtitle A, Sec 4101(a)

In the case of an EP who provides covered professional services in an area designated, by the Secretary as a health professional shortage area (HSPA), the amount of their incentive shall be increased by 10 percent. The payment schedule below helps to illustrate this additional incentive through the Medicare Fee-for Service program.*

CFR 42 § 495.102(c), Page 260
Section II.B.1.c (Pages 132 - 133) of the CMS Final Rule
Division B, Title IV, Subtitle A, Sec 4101(a)

What are the penalties associated with not using a certified EHR technology in a meaningful way?
Penalties will be implemented through payment adjustments to fee schedule reimbursements made to EPs for covered professional services. If an EP hasn't demonstrated meaningful use successfully by 2015 or each year after they are subject to the Medicare penalties. The EP's fee schedule reimbursement amount will be reduced to 99 percent in 2015, 98 percent in 2016, and 97 percent in 2017 and in each subsequent year for all covered professional services. For 2018 and each subsequent year, if the Secretary finds that the proportion of eligible professionals who are meaningful EHR users is less than 75 percent, the applicable fee schedule amount will be decreased by one percentage point from the applicable percent in the preceding year, but in no case will the applicable percent be less than 95 percent.

The Secretary on a case-by-case basis may EPs from the payment adjustment if the requirements to be a meaningful user pose a significant hardship on the EP. An example would be in the case of an EP who practices in a rural area without sufficient internet access. Exemptions are subject to annual renewal and will not be granted for more than five years.

CMS will propose more detailed regulations prior to the 2015 implementation date of the Medicare Fee-for Service Penalties.

CFR 42 § 495.102(d), Pages 260-261
Section II.B.1.e (Pages 135 - 136) of the CMS Final Rule

What's a Medicare incentive payment example?
Provider A Example
Provider A becomes a meaningful user of a certified EHR technology by the beginning of 2011 and reports all the appropriate measures and information to CMS beginning in 2011 through the end of the program. Provider A also submits $25,000 worth of allowable charges to Medicare each year in 2011 through 2015. Provider A's incentive schedule will look like this:

Date of Certified EHR Adoption: January 1, 2011
Date of Meaningful Use: January 1, 2011
Practice in a Health Professional Shortage Area: No

Provider B Example
Provider B adopts an electronic record in 2011 but does not become a meaningful user until 2013. Provider B submits $15,000 worth of allowable charges to Medicare each year in 2011 through 2016. Provider B's incentive schedule will look like this:

Date of Certified EHR Adoption: January 1, 2011
Date of Meaningful Use: January 1, 2013
Practice in a Health Professional Shortage Area: Yes*

What's a Medicare payment adjustment example?
Provider A Example
Provider A does not adopt a qualified certified electronic health record until after the adjustment begins. If the same payment information holds true from above, Provider A's payment adjustment would look like this between 2015 and 2019:

Date of Certified EHR Adoption: N/A
Date of Meaningful Use: N/A
Practice in a Health Professional Shortage Area: No

When will Medicaid incentive payments begin?
There is no statutory implementation date for the Medicaid Incentive Program because it will be implemented by each state. CMS has indicated that some states may be prepared to implement their program and make EHR incentive payments as early as 2010 for adopting, implementing or upgrading certified EHR technology. States will need to demonstrate their readiness to CMS prior to starting their Medicaid Incentive Program.

Who is an eligible professional (EP)?
The Medicaid Incentive Program defines an EP using the same definition as the Medicare Fee-for Service Program, but also includes additional providers and requirements. Medicare defines EP from Section 1861(r) of the Social Security Act. An EP is:

1. a doctor of medicine or osteopathy
2. a doctor of dental surgery or dental medicine
3. a doctor of podiatric medicine
4. a doctor of optometry
5. a chiropractor

All of which must be legally authorized to practice medicine, surgery, or other care by the state in which they perform such functions or actions. The Medicaid Incentive Program adds on to this definition to include:

1. a dentist
2. a certified nurse mid-wife
3. a nurse practitioner
4. a physician assistant practicing in a Rural Health Clinic (RHC) or a Federally Qualified Health Center (FQHC)

All of these providers are also subject to the following three patient threshold requirements to qualify as a Medicaid EP:

1. A non-hospital-based provider with at least 30 percent of patient volume attributable to individuals receiving Medicaid Assistance
2. A non-hospital-based pediatrician with at least 20 percent of patient volume attributable to individuals receiving Medicaid assistance
3. A non-hospital-based provider practicing predominately in a Federally Qualified Health Center or rural health clinic with at least 30 percent of patient volume attributable to needy individuals

CFR 42 § 495.304, Page 266
Section II.D.3.c (Pages 173 – 174) of the CMS Final Rule

What are the average allowable costs for the Medicaid incentive?
The average allowable costs are broken into two categories which are associated with the years of payment. The ARRA outlined that the Secretary of HHS was to conduct a study on EHR technology to identify the average allowable costs in each of these categories. The first category is linked to the first year of payment for an eligible professional (EP). In the first year of payment the average allowable costs are the costs associated with the purchase and initial implementation or upgrade of a certified EHR technology (and support services including training that is for the adoption and initial operation of, such technology).

The second category is tied to each subsequent year after the first year of payment. In each subsequent year the average allowable costs are the costs relating to the operation, maintenance, and use of a certified EHR technology.

CMS has proposed that the average allowable costs for the first year of payment be set at $54,000. For subsequent payment years the average allowable cost is proposed to be set at $20,610.

The ARRA capped the Medicaid Incentive Payments at 85% of the net average allowable cost of $25,000 in the first year and $10,000 in each subsequent year. What this means is that Medicaid EPs can receive $29,000 (54,000-25,000=29,000) from other sources in the first year and $10,610 (20,610-10,000=10,610) in each subsequent year. Other sources would include other federal and state assistant or incentive programs like the e-prescribing incentive offered through the Medicare Improvements for Patients and Providers Act (MIPPA) of 2008.

CFR 42 § 495.308, Page 267
Section II.D.4.a.(2) (Page 180) of the CMS Final Rule

If an eligible professional qualifies for both the Medicare and Medicaid programs and selects Medicaid, but doesn’t begin implementing until 2016 are they subject to the penalties under the Medicare program?
Currently there are two ways an eligible professional (EP) submitting eligible Medicare charges can avoid receiving payment adjustments. The first is by implementing and demonstrating meaningful use of a certified EHR technology and the second would be to qualify for a significant hardship exemption.

Significant hardship exemptions may be granted on a case-by-case basis by the Secretary of HHS on a year-by-year basis. EPs cannot be granted this exemption for more than 5 years.

CMS indicated in the Final Rule that the payment adjustments will apply to Medicaid EPs who also qualify as a Medicare EP, so the EP who qualifies for both and doesn't begin implementing until 2016 will be subject to the payment adjustments in the prior years.

Section II.B.1.e (Pages 135-136) of the CMS Final Rule

How are needy individuals defined?
A needy individual means an individual that meets one of the following:

• Received medical assistance from Medicaid or the Children's Health Insurance Program (or a Medicaid or CHIP demonstration program approved under section 1115 of the Act)
• Were furnished uncompensated care by the provider
• Were furnished services at either no cost or reduced cost based on a sliding scale determined by the individuals' ability to pay

CFR 42 § 495.302 (Needy individuals), Page 266

How is "meaningful use" defined for the Medicaid Program?
Meaningful use under the Medicaid Incentive Program is demonstrated through a means that is approved by the State and accepted by the Secretary. The approved method the State selects needs to be consistent with the requirements outlined in the Medicare meaningful use section.

CFR 42 § 495.314, Page 269

How is an electronic health record identified as a certified EHR?
The same certification criteria that apply to the Medicare Incentive Program also apply to the Medicaid Incentive Program.

How much are the incentives?
The Medicaid Incentive Program authorizes states to make payment to Medicaid EPs totaling no more than 85 percent of net average allowable costs for the purchase, upgrade, implementation or use of a certified EHR technology. The incentive is capped at 85 percent of $25,000 ($21,250) on a per provider basis in the first year of payment which may not be later than 2016. Each subsequent year after the first payment year is capped at 85 percent of $10,000 ($8,500) per provider and cannot be paid over a period longer than five years. EPs are eligible for a total of $63,750 over the six years of the program.*

No EP qualifying for the program after 2016 may receive payment so the final year an EP could receive payment would be in 2021. The Medicaid incentive schedule is also adjusted for non-hospital-based pediatricians with at least 20 percent of patient volume, but less than 30 percent attributable to individuals receiving Medicaid assistance. For these providers their maximum allowable incentive is capped at two-thirds of the other amounts. Therefore pediatricians qualifying under this program could receive a maximum incentive of $42,500, over the six years of the program.

Incentive Schedule for Medicaid Eligible Professionals (EPs)

Incentive Schedule for Medicaid Pediatric EPs

CFR 42 § 495.310 (Pages 267-268)
Section II.D.4.a.(4) (Pages 179 – 185) of the CMS Final Rule

*The incentives represented on this page are the maximum that are allowed under the American Recovery and Reinvestment Act of 2009. The actual incentive payment will vary by provider based on the provider's total reimbursement from Medicare and Medicaid. The Medicaid incentive payments may also vary based on the level of support provided from other Federal and State organizations to adopt a certified EHR technology that is being implemented. Each organization should directly review the American Recovery and Reinvestment Act of 2009 and subsequent federal regulations for complete details and determination of how it would apply.

Does Your Practice Qualify for the Medicare and Medicaid EHR Incentive Programs?

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