Comparing the Medicare and Medicaid
EHR Incentive Programs
By Kevin Heubusch
APPROXIMATELY 77,000 HEALTHCARE providers had regis- tered for the meaningful use EHR incentive programs through July, program officials told the Health IT Policy Committee at its August 3 meeting. That is a significant number, but it leaves plenty of eligible providers and hospitals still to register. For those that have not, a first step is determining their eli- gibility. The Medicare and Medicaid incentive programs vary in notable ways, from the types of providers who qualify to the payments and penalties possible. Professionals eligible for both programs must pick one. Eligibility Requirements
Eligibility requirements differ between the programs, as shown
in the sidebar. Doctors of medicine are eligible for either program, for example, but nurse practitioners and certain physician assistants can only participate in the Medicaid program.
Professionals eligible for both programs must select one when
they register. They do get a chance to change their minds, however. After receiving the first incentive payment, they may switch
programs once before 2015.
Select hospitals also are eligible for both programs. CMS recommends they register for both, even if they plan to apply for incentives only under one, because they will not be able to manually change their registration after a payment is initiated.
Eligible professionals who are hospital-based are not eligible
for incentive payments. For purposes of the program, an eligible
professional is considered hospital-based if he or she performs
90 percent or more of his or her services in a hospital inpatient
or emergency room setting (Place of Service codes 21 and 23).
Each eligible professional in a group practice may qualify for
an incentive payment.
Comparing the Eligibility Requirments
ELIGIBILITY REQUIREMENTS DIFFER between the programs. Professionals who are eligible for both programs
must choose between them when they register.
Doctors of medicine or
Doctors of dental surgery
or dental medicine
Physicians (primarily doctors
of medicine and doctors of
Doctors of podiatry
Doctors of optometry
Subsection (d) hospitals in
the 50 states or DC that are
paid under the Inpatient
Prospective Payment System
Critical access hospitals
Physician assistants who furnish
services in a federally qualified
health center or rural health
clinic that is led by a physician
Acute care hospitals (including
critical access hospitals and
cancer hospitals) with at least
10 percent Medicaid patient