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Frequently Asked Questions: Medicaid HIT Incentive Payments for Eligible Professionals (Title IV, Section, Section 4201, pp. 375-380)

What types of professionals are eligible for Medicaid incentive payments?

When will the incentive payment program begin, and how much incentive funding is available for eligible professionals?

Are non-hospital-based clinicians with few to no Medicaid patients eligible for the incentive payments?

If a practice is owned by a hospital, can the eligible professionals in this practice still receive Medicaid incentive payments?

Is the funding available upfront to help eligible professionals purchase an EHR system, or will the eligible professional only receive incentive payments after implementation?

Is each eligible professional that meaningfully uses an EHR in a group practice eligible for incentives payments or just the group practice itself?


Answers

What types of professionals are eligible for Medicaid incentive payments?
Eligible professionals include physicians, dentists, certified nurse midwives, nurse practitioner, and physician assistants practicing in rural health clinics or Federally-Qualified Health Centers (FQHC) led by a physician assistant. These eligible professionals must have at least a 30% patient volume attributable to Medicaid and/or BadgerCare Plus. Eligible professionals practicing in a FQHC or rural health center must have at least 30% patient volume attributable to Medicaid or needy individuals. The legislation does not indicate how CMS or the State must determine or calculate an eligible professional's patient volume percentage. These details will be addressed as part of the regulatory process in the coming months (p. 377).

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When will the incentive payment program begin, and how much incentive funding is available for eligible professionals?
The Medicaid incentive payment program will begin January 1, 2011 for eligible professionals. An eligible professional can receive Medicaid incentive payments over a 6-year period with a first-year payment of up to $21,250 and five subsequent annual payments of up to $8,500. The eligible professional must demonstrate meaningful use of a certified EHR by the second payment year. A potential Medicaid payment schedule is displayed below.


Note: Pediatricians must have a Medicaid patient volume of 20% to be eligible and get 2/3 of the dollar amounts specified above unless their Medicaid patient volume is 30% or higher

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Are non-hospital-based professionals with few to no Medicaid patients eligible for the incentive payments?
No, eligible professionals must have at least 30% patient volume attributable to Medicaid and/or BadgerCare Plus patients. Eligible professionals practicing in a FQHC or rural health center must have at least 30% patient volume attributable to Medicaid and/or needy individuals (pp. 375-376).

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If a practice is owned by a hospital, can the eligible professionals in the practice receive Medicaid incentive payments?
If for a payment year an eligible professional, such as a pathologist, anesthesiologist, or emergency physician, furnishes substantially all services in a hospital setting (whether inpatient or outpatient) and through the use of the facilities and equipment, including qualified electronic health records, of the hospital, the physician is not eligible for incentive payments because the hospital incurs the EHR system expense. Final physician eligibility determination criteria have not yet been defined by HHS. The ARRA does contain incentives specifically for hospitals.

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Is the funding available upfront to help an eligible professional purchase an EHR system, or will the eligible professional only receive incentive payments after implementation?
Through 2016, eligible professionals can receive a one-time incentive payment for 85% of net average allowable costs (not to exceed $25,000 or less based on HHS studies of average costs) for the purchase, and initial implementation and upgrade of a certified EHR technology, including support services and training. After acquiring an EHR and receiving the first incentive payment, eligible professionals can then subsequently receive incentive payments for up to 5 years (but not beyond 2021) for the net average allowable costs to operate, maintain, and use their EHR (allowable cap per year is $10K or less based on HHS studies of average costs) if they meet the definition of a meaningful EHR user in accordance with the regulations set forth by the HHS Secretary. A Medicaid provider who has completed adopting and implementing, or upgrading to a certified EHR technology prior to 2011 must be a meaningful EHR user to receive the first payment as well as subsequent payments.

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Is each eligible professional that meaningfully uses an EHR in a group practice eligible for incentive payments or just the group practice itself?
The funding is available per physician. Final regulations will outline the physician identifier to use, which may be an NPI number or a Social Security number.

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Last Revised: July 12, 2010