The following providers are considered Eligible Professionals (EPs) for the Medicaid EHR Incentive Program:
- Physicians (Doctors of Medicine [MD] and Doctors of Osteopathy [DO])
- Nurse Practitioners
- Psychiatric Clinical Nurse Specialists (as of program year 2016)
- Certified Nurse-Midwives
- Physician Assistants in a leadership position (Medical Director, CEO, or CIO)
at a Federally Qualified Health Center (FQHC) or Rural Health Clinic (RHC)
Exclusion: EPs are considered hospital-based if 90% or more of their encounters occur at an inpatient (POS 21) or ER department (POS 23) setting. These EPs are not eligible to participate in the program, except if they contributed funds to the acquisition, implementation and maintenance of Certified EHR Technology (CEHRT) hardware and interfaces to meet Meaningful Use.
Medicaid Patient Volume
EPs must meet a 30% Medicaid Patient Volume Threshold during a 90 day reporting period, selected from either the previous calendar year or the 12 month period leading up to their attestation date. If their Medicaid Patient Volume satisfies the threshold, EPs can earn up to $63,750 in incentives over a 6-year period: $21,250 in the first year of participation and $8,500 in years 2 through 6. For details view this CMS presentation
Board-Certified Pediatricians can also qualify if they meet a 20% threshold, but in this case the incentive is reduced to $42,500 ($14,167 year 1, and $5,667 years 2 to 6). Non-certified pediatricians must meet the 30% threshold.
Medicaid Patient Volume
Number of Medicaid Patient Encounters during a 90 Day Reporting Period.
Medicaid Patient Encounter
One service per day, where Medicaid or Medicaid 1115 Waiver paid for all or part of the services.
90 Day Reporting Period
90 day consecutive period during the current calendar year, or within the 12 months preceding attestation. EPs can choose the 90 day period they want to use to attest.
EPs are considered to “practice predominately” at an FQHC or RHC if 50% or more of their encounters over a 6 month period in the current calendar year occur at an FQHC or RHC.
EPs who "practice predominantly" at an FQHC or RHC can base their Medicaid Patient Volume on services provided to Medicaid and Needy Individuals, which includes:
- Medicaid Population (FFS);
- Medicaid 1115 Waiver Population (MCO);
- Uncompensated Care; and
- Services furnished at no cost or at a reduced cost based on the individual’s ability to pay.
Alternatively, these EPs can choose to report their volume based on the Non-FQHC/RHC Method.
All other EPs must base their Medicaid Patient Volume on services to Medicaid individuals, which includes:
- Medicaid Population (FFS); and
- Medicaid 1115 Waiver Population (MCO).
In this case, CMS requires that Children’s Health Insurance Program (CHIP) patients are excluded from the Medicaid Patient Volume. A CHIP reduction factor must be applied to an EP's in-state Medicaid Patient Volume to fill this requirement. This CHIP factor varies quarterly or annually.
A/I/U and Meaningful Use Incentives
- For the first year of participation, EPs were able to earn an incentive for Adopting, Implementing or Upgrading to CEHRT (A/I/U).
As of Program Year 2017: EPs can no longer initiate participation and the A/I/U incentives are no longer available.
- EPs can continue to earn incentives for the Meaningful Use of CEHRT (MU), up to Program Year 2021.
As of Program Year 2017: The MU incentives are available only to participants who attested and were paid A/I/U and/or MU incentives for prior Program Years.
Participation years don't need to be consecutive as EPs can skip years, which merely delays their incentive payments.
For more details about participation and the incentive payments, read Provider FAQ fact sheet
Note: In Feb 2013, the IRS determined that the EHR incentive payments are taxable income.
Medicare versus Medicaid EHR Incentive Program
Originally, EPs could choose to participate in the Medicare EHR Incentive Program. EPs could not participate in both programs, but over the course of participation, EPs were allowed to switch once between the Medicare and Medicaid programs.
The last year to start participation in the Medicare EHR Incentive Program was 2014 and the program ended in 2016. EPs who started attesting in or before 2012, could earn up to $44,000 in financial incentives. For more details on the Medicare EHR Incentive Program visit the CMS website or view this CMS presentation
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If you have questions, please contact the MeHI Services Center via phone, Monday - Friday between the hours of 9:00 am and 4:30 pm, or via email any time. Information can also be found on the MassHealth website.