Eligible hospitals (EHs) and eligible professionals (EPs) can receive incentive payments through the Medicare and Medicaid EHR Incentive Programs by demonstrating meaningful use (MU) of certified EHR technology. MU requirements differ for EHs and EPs.
EHs: Who Qualifies?
EHs under the Medicaid EHR Incentive Program include:
- Acute-care hospitals (including Critical Access Hospitals [CAHs] and cancer hospitals)
- Children's hospitals (no Medicaid patient volume requirements)
EHs under the Medicare EHR Incentive Program include:
- "Subsection (d) hospitals" in the 50 states or DC that are paid under the Inpatient Prospective Payment System (IPPS)
- Medicare Advantage (MA-Affiliated) Hospitals
All hospitals that are part of The Indian Health Service (IHS), including CAHs, are dual-eligible; in other words, they are allowed to receive EHR incentive payments from both Medicaid and Medicare simultaneously, provided they meet all of the certification and eligibility requirements.
EPs: Who Qualifies?
Depending on their specialty, some professionals are eligible to participate in both the Medicare and the Medicaid EHR Incentive Programs. Other professionals, however, are only eligible to participate in one program. For example, those professionals who are only eligible to participate in the Medicare program include:
- Doctors of optometry
- Doctors of podiatric medicine
Other professionals are only eligible to participate in the Medicaid program. These individuals include:
- Nurse practitioners
- Certified nurse midwives
- Physician assistants (PAs) who work at federally qualified health centers (FQHCs) or rural health centers (RHCs) when (1) a PA is the primary provider in the clinic; (2) a PA is a clinical or medical director at the clinic; or (3) a PA owns the RHC
Even though some professionals are eligible to participate in both Medicare and Medicaid, they are only allowed to participate in one program at a time and must choose which one they prefer. Likewise, they are only eligible for one incentive payment per year, regardless of the number of practices or locations for which they provide services. These professionals include:
- Doctors of medicine
- Doctors of osteopathy
- Doctors of dental medicine or surgery
Hospital-based professionals, however, are not eligible to receive either Medicare or Medicaid payments as part of the EHR incentive program. A professional is considered hospital-based if at least 90 percent of his or her services are performed in a hospital inpatient or emergency room setting (Place of Service code 21 or 23).