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SUMMARY OF THE
MEDICARE AND
MEDICAID ELECTRONIC
HEALTH RECORD
INCENTIVE PROGRAM
FINAL RULE
September 2010
TABLE OF CONTENTS
I. Overview ...................................................................................................................................... 1
II. Summary of the Meaningful Use Qualifying Process .................................................................. 2
III. Legislative Mandate ..................................................................................................................... 3
IV. Eligible Providers ......................................................................................................................... 3
Medicare Eligible Hospitals ................................................................................................... 3
Medicare Eligible Professionals ............................................................................................. 3
Medicaid Eligible Hospitals ................................................................................................... 4
Medicaid Eligible Professionals ............................................................................................. 5
V. Meaningful Use ............................................................................................................................ 6
Payment Year ......................................................................................................................... 6
EHR Reporting Period ............................................................................................................ 7
Certified EHR Technology ..................................................................................................... 7
Meaningful Use Criteria ......................................................................................................... 7
Proposed Stage 1 Meaningful Use Criteria for Eligible Hospitals and Professionals ............ 9
Common Definition of Meaningful Use under Medicare and Medicaid ............................. 13
Medicaid Exception for First Year of Participation ............................................................. 14
VI. Clinical Quality Measure Reporting ........................................................................................... 14
Reporting Requirements ....................................................................................................... 14
Hospital Clinical Quality Measures ..................................................................................... 15
Clinical Quality Measures for Electronic Submission by Eligible Hospitals for Stage 1 .... 16
Physician Clinical Quality Measures ................................................................................... 19
VII. Incentive Payment Calculation ................................................................................................... 20
Medicare Incentive Payments for Hospitals ......................................................................... 20
Medicare Incentive Payments for CAHs .............................................................................. 22
Medicare Incentive Payments for EPs .................................................................................. 23
Medicaid Incentive Payments for Hospitals (including CAHs) ........................................... 24
Medicaid Incentive Payments for EPs .................................................................................. 25
If you have any questions about this summary, contact Kathy Reep, FHA Vice President/Financial
Services, by email at [email protected] or by phone at (407) 841-6230.
1
I. OVERVIEW
The Centers for Medicare & Medicaid Services (CMS) published the final Medicare and Medicaid
Programs; Electronic Health Record Incentive Program rule in the July 28, 2010 Federal Register.
This document provides an overview of the final rule. Additional information regarding the rule is
available on the CMS Web site at http://www.cms.gov/EHRIncentivePrograms/.
Note: Text in italics is extracted from the July 28 Federal Register.
The Final Rule includes:
Definition of Eligible Providers – The electronic health record (EHR) incentive program applies to
doctors and hospitals that meet the eligibility criteria. The criteria are slightly different between the
Medicare and Medicaid programs.
Medicare eligible hospitals - An eligible hospital (EHs) under the Medicare program is any
“subsection (d) hospital” that is paid under the inpatient prospective payment system (IPPS) or
a certified Critical Access Hospital (CAH). This definition excludes cancer hospitals and
children’s hospitals from eligibility for EHR payment incentives under Medicare.
Medicaid eligible hospitals – An EH under the Medicaid program definition, short-term,
inpatient acute care hospitals (including CAHs, cancer hospitals, and children’s hospitals) are
eligible. The hospital must have at least 10 percent of its patient volume attributable to
Medicaid beneficiaries (children’s hospitals are exempted from this volume threshold).
An eligible professional may only receive EHR incentive payments from one program – either
Medicare or Medicaid.
Medicare eligible professionals – An eligible professional (EP) provider must be a doctor of
medicine or osteopathy, a doctor of dental surgery or dental medicine, a doctor of podiatric
medicine, a doctor of optometry, or a chiropractor. The professional must be legally authorized
to practice under state law. Hospital-based professionals, defined as professionals who provide
90 percent or more of their services in a hospital inpatient and/or emergency department setting,
do not meet the eligibility definition.
Medicaid eligible professionals – An EP under the Medicaid program must be non-hospital-
based physicians, dentists, nurse practitioners, certified nurse midwives, and physician
assistants. The definition of hospital-based is the same as for the Medicare program, with the
exception of services provided in Federally Qualified Health Clinics (FQHCs) or Rural Health
Clinics (RHCs). A Medicaid EP must have at least 30 percent of his/her patient volume
attributable to Medicaid patients – with some exceptions.
Definition of Meaningful Use – CMS intends to define three stages of meaningful use, with the
qualifying criteria becoming more stringent over time. The final rule establishes the Stage 1 criteria,
requiring eligible hospitals and professionals to use certified electronic health records (EHRs) and have
the capacity to capture and report specific data elements. A related regulation has been published by
the Office of the National Coordinator of Health Information Technology (ONC) regarding the criteria
2
for certified EHRs. Stage 1 criteria will apply to all eligible hospitals and professionals that first
qualify for the EHR incentive program during the 2011 through 2014 payment years. CMS will define
its criteria for Stages 2 and 3 in future rulemaking.
There are 14 “core” criteria and another 10 “menu” criteria for EHs; there are 15 core and 10 menu
criteria for EPs.
Quality Measure Reporting – One of the Stage 1 core criteria for meaningful use is the ability to use
EHRs to report on a set of clinical quality measures (15 for EHs and 6 for EPs). All of the measures
have been endorsed by the National Quality Forum (NQF) and adopted by the Health Quality Alliance
(HQA).
Incentive Payment Calculation – CMS outlines its methodology for determining Medicare EHR
incentive payments and provides guidelines for states to determine Medicaid EHR incentive payments.
Payment Reduction Calculation – The rule outlines the Medicare payment reduction penalty that will
be applied to those eligible providers and hospitals that do not meet the meaningful use criteria by
FY2015. There will be no payment penalties under the Medicaid program.
II. SUMMARY OF THE MEANINGFUL USE QUALIFYING PROCESS
1. Verify Eligibility
See section on Eligible Providers
2. Register for the EHR Incentive Program
CMS will establish online provider registration at its EHR Web site:
www.cms.gov/EHRIncentivePrograms/
CMS will post on its Web site the name, business address, and business phone number of all
EPs, eligible hospitals, and CAHs participating in the Medicare EHR incentive program.
Medicaid EPs and eligible hospitals are not required to be identified online.
3. Ensure EHR Technology is Certified
The ONC has issued companion rules with details on selection of certifying bodies and the
criteria and process for seeking certification of EHR technology.
4. Become a Meaningful User of Certified EHR
See sections on Meaningful Use and Clinical Quality Measure Reporting
5. Attest to Meaningful Use
CMS will require that EPs, eligible hospitals, and CAHs attest to meaningful use via a secure
online portal. CMS will be issuing additional guidance on this mechanism as it is developed.
A one-time attestation following the completing of the EHR reporting period for a given
payment year will be required for EPs and eligible hospitals to identify the certified EHR they
are using and their performance on all the measures.
3
States will include information on the Medicaid attestation process in their State Medicaid HIT
plans.
6. Receive Incentive Payments
See section on Incentive Payments
III. LEGISLATIVE MANDATE
The final rule implements provisions of the American Recovery and Reinvestment Act of 2009
(ARRA). Title XIII of Division A and Title IV of Division B of the ARRA are cited as the “Health
Information Technology for Economic and Clinical Health” or HITECH Act. The HITECH provisions
of the ARRA amend the Social Security Act by establishing incentive payments to eligible
professionals and eligible hospitals that adopt health information technology and EHRs in such a way
as to become meaningful users.
IV. ELIGIBLE PROVIDERS
The EHR incentive program is only available to certain providers, hospitals and physicians, and the
program’s eligibility requirements are different for Medicare and Medicaid.
Medicare Eligible Hospitals
Federal Register pages 44448 - 44450
CMS Proposal: CMS proposed to use the definition of subsection (d) hospitals from the Social
Security Act to define eligible hospitals for the Medicare EHR incentive program. CMS’ interpretation
of the Social Security Act is that an eligible hospital must be located in one of the fifty states or the
District of Columbia; therefore, hospitals in Puerto Rico would not be eligible. Subsection (d) hospitals
also do not include hospitals excluded from payments under the IPPS such as psychiatric,
rehabilitation, long term care, children’s, or cancer hospitals. Acute care hospitals in the state of
Maryland would be considered eligible because they are operating under a special waiver.
CMS proposed that eligible hospitals be identified based upon their unique Medicare provider number.
Using this method, hospitals with multiple, discrete campuses that operate under one Medicare provider
number will be recognized as one provider, regardless of how many separate provider IDs, financial
filings, etc. they may maintain.
Final Rule: Despite receiving numerous comments from providers and their associations regarding the
disadvantageous impact of this definition on hospitals that operate multiple campuses under one
Medicare provider number, CMS has adopted its proposed definition as final. Specialty hospitals are
excluded from Medicare eligibility under the program.
Medicare Eligible Professionals
Federal Register page 44442
CMS’ Proposal: “. . . we propose to add a definition of the term ‘eligible professional’ . . . to mean a
physician as defined under section 1861(r) of the Act. Section 1861(r) of the Act defines the term
‘physician’ to mean the following five types of professionals, each of which must be legally authorized
4
to practice their profession under state law: a doctor of medicine or osteopathy, a doctor of dental
surgery or dental medicine, a doctor of podiatric medicine, a doctor of optometry, or a chiropractor.”
A Medicare eligible professional (EP) must provide services that are covered by the Medicare program
and are paid according to the Medicare physician fee schedule. The HITECH Act specifies that
hospital-based professionals are not eligible for the EHR incentive program. CMS’ original proposal
defined a hospital-based EP as a professional who furnishes 90 percent or more of his/her allowed
services in a hospital setting – including all hospital inpatient, outpatient, and emergency department
settings.
Final Rule: CMS is adopting as final its definition of an eligible professional; however, the definition
for hospital-based has been revised to include only those professionals who furnish 90 percent or more
of their allowed services in a hospital inpatient or emergency department setting. The determination of
hospital-based vs. non-hospital-based status will be made based upon the place of service (POS) codes
on the Medicare bills.
CMS intends to use the Medicare physician claims database to determine the list of non-hospital-based
EPs on an annual basis. That list will be made publicly available.
EPs who meet the eligibility requirements for both the Medicare and Medicaid EHR incentive
programs may participate in only one program and must designate, upon registration for the program,
which payer they choose. After the initial designation, EPs will be allowed to change their payer
selection only once (prior to FY2015) during the incentive payment years.
Medicaid Eligible Hospitals
Federal Register pages 44484 - 44485
CMS’ Proposal: The HITECH Act specifies that, for Medicaid EHR incentive payments, only acute
care and children’s hospitals are eligible. CMS originally proposed to define an acute care hospital as
an inpatient healthcare facility with an average length of stay of 25 days or less. CMS proposed to use
Medicare provider numbers (CMS Certification Number or CCN) where the last four digits are between
0001 and 0879 as the means for identifying eligible acute care hospitals and where the last four digits
of the CCN are between 3300 and 3399 for identifying children’s hospitals. Using this classification
method, cancer hospitals would be eligible, but CAHs and specialty hospitals (long term care hospitals,
rehabilitation hospitals, psychiatric hospitals, skilled nursing facilities) were excluded.
Final Rule: Based on the comments it received, CMS is amending its definition of acute care hospital
for the purpose of the Medicaid EHR incentive payment program as “. . . those hospitals with an
average patient length of stay of 25 days or fewer, and with a CCN that falls in the range of 0001-0879
or 1300-1399. This definition will now encompass general short term hospitals, cancer hospitals, and
critical access hospitals that meet the Medicaid patient volume criteria.” CMS is not developing a
separate Medicaid incentive payment calculation for CAHs. States will determine Medicaid incentive
payments to qualifying CAHs using the same methodology as for acute hospitals. The definition for
children’s hospitals did not change.
Eligible hospitals (except children’s hospitals) must meet a minimum Medicaid volume threshold of 10
percent, including Medicaid managed care. The Medicaid patient volume threshold will be calculated
5
using total Medicaid encounters for any representative 90-day period in the preceding calendar year.
CMS provides some details on how the patient volume threshold may be calculated, offering two
options to the states. Each state may choose one of the two options or a state-proposed alternative, if
approved by CMS. “A Medicaid provider may demonstrate patient volume by: 1) having patient
encounters within the 90-day period by using the same methodology we proposed in the proposed rule;
2) having a Medicaid enrollee on the panel assigned to the EP (for example, managed care or medical
homes) within that representative 90-day period.”
In response to comments asking for further clarification of the term “encounter,” CMS provides the
following clarifying language: “For purposes of calculating hospital patient volume, we have allowed
the following to be considered Medicaid encounters: 1) services rendered to an individual for inpatient
discharges where Medicaid or a Medicaid demo project paid for part or all of the services; 2) services
rendered on any one day to an individual for where Medicaid or a Medicaid demo project paid all or
part of their premiums, co-payments, and/or cost sharing; 3) services rendered to an individual in an
emergency department where Medicaid or a Medicaid demo project paid for part or all of the services;
4) services rendered on any one day to an individual in an emergency department where Medicaid or a
Medicaid demo project paid all or part of their premiums, co-payments, and/or cost sharing.”
Similar to the Medicare eligibility requirements, hospitals with multiple, discrete campuses that operate
with one CCN will be recognized as one provider, regardless of how many separate provider IDs,
financial filings, etc. they may maintain. CMS did not revise its proposed policy on this issue.
Medicaid Eligible Professionals (EPs)
Federal Register page 44485
CMS’ Proposal: CMS listed five types of Medicaid professionals that meet the definition of an EP: “.
. . physicians, dentists, certified nurse-midwives, nurse practitioners, and physician assistants
practicing in an FQHC or RHC that is led by a physician assistant.”
Per statute, a Medicaid EP may not be hospital-based. CMS proposed to use the same definition of
hospital-based for Medicaid as it proposed for Medicare.
Final Rule: CMS is clarifying that the Medicaid definition of physician is “. . . limited to doctors of
medicine or osteopathy legally authorized to practice in their state, and in cases where States have
specifically adopted the option in their State plans, optometrists.” Regarding specialty providers, CMS
clarifies that “. . . so long as an EP qualifies as a practitioner within the State’s scope of practice rules
for each of the five EP types, they are eligible for this program. In other words, since pediatricians are
physicians, they must meet the physician scope of practice rules and then they may be eligible for an
incentive when they meet all other requirements . . . . Eligible provider types must be specified in a
State’s SMHP.”
CMS has revised its definition for hospital-based EPs to include only those professionals who furnish
90 percent or more of their allowed services in a hospital inpatient or emergency department setting.
The determination of hospital-based vs. non-hospital-based status will be made based upon the place of
service (POS) codes on the Medicare bills.
6
EPs must meet a Medicaid volume threshold of 30 percent (20 percent for pediatricians), that will be
calculated in the same manner, using the same definitions, and with the same state discretion as for
hospitals. The Medicaid volume threshold must include Medicaid beneficiaries enrolled in managed
care plans, prepaid inpatient health plans, and prepaid ambulatory health plans.
EPs that practice predominantly in an FQHC or RHC must meet a needy individual threshold of 30
percent (or 20 percent for pediatricians). Needy individuals are defined as persons receiving medical
assistance from Medicaid, the Children’s Health Insurance Program (CHIP), or based on some other
auditable reduced payment scale.
EPs who meet the eligibility requirements for both the Medicare and Medicaid EHR incentive
programs may participate in only one program and must designate, upon registration for the program,
which payer they choose. After the initial designation, EPs will be allowed to change their payer
selection only once (prior to FY2015) during the incentive payment years.
V. MEANINGFUL USE
Per statute and the CMS rule, a meaningful user of certified EHR technology is “. . . an EP or eligible
hospital who, for an EHR reporting period for a payment year, demonstrates meaningful use of
certified EHR technology in the form and manner consistent with our standards . . .” See “Eligible
Providers” section above for the Medicare and Medicaid eligible hospitals and professionals definitions
and criteria.
Payment Year
Federal Register pages 44318 - 44319
CMS’ Proposal: “For all EPs, we are proposing a common definition for both ‘payment year’ and
‘year of payment,’ as any calendar year beginning with 2011 . . . because hospitals will have the
opportunity to simultaneously participate in both the Medicare and Medicaid EHR incentive programs,
we propose a common definition of ‘payment year’ and ‘year of payment’ for both programs . . . as any
fiscal year beginning in 2011.”
Final Rule: CMS is adopting as final its proposal for defining payment years for EPs and eligible
hospitals. Hence, a payment year for physicians is defined as a calendar year, while a payment year for
hospitals would be the federal fiscal year (October 1 through September 30). These definitions apply
under both the Medicare and Medicaid programs.
CMS goes on to clarify that, for the Medicare program, payment years must be successive after the first
payment year. “This requirement, that each payment year ‘immediately follow’ the prior year, means
that every year subsequent to the first payment year is a payment year regardless of whether an
incentive payment is received by the EP, eligible hospital or CAH. For example, if a Medicare EP
receives an incentive in CY2011, but does not successfully demonstrate meaningful use or otherwise
fails to qualify for the incentive in CY2012, CY2012 still counts as one of the EP’s five payment years
and they would only be able to receive an incentive under the Medicare EHR incentive program for
three more years as CY2013 would be there (sic) third payment year.” This same rule does not apply
to incentive payments under the Medicaid program – payments (and payment years) may be non-
7
consecutive; however, starting in 2016, payments must be made every year in order to continue
participation in the program.
EHR Reporting Period
Federal Register page 44320
CMS’ Proposal: “In this proposed rule, we propose a definition of EHR Reporting Period for
purposes of Medicare and Medicaid incentive payments . . . . For these sections, the EHR reporting
period may be any continuous 90-day period within the first payment year and the entire payment year
for all subsequent payment years. In future rulemaking, we will propose a definition of EHR Reporting
Period for purposes of Medicare incentive payment adjustments . . . .”
Final Rule: CMS is adopting as final its proposal that the EHR reporting period is any continuous 90-
day period within the first payment year and the entire payment year for all subsequent years.
However, CMS clarifies that “. . . an EHR reporting period for demonstrating adoption,
implementation or upgrading certified EHR technology by Medicaid EPs and eligible hospitals is
unnecessary. . . .” (See the section on Medicaid Exception for the First Year, below.) Therefore, “. . .
Medicaid EPs and eligible hospitals who are demonstrating meaningful use for the first time in their
second payment year, will have a 90-day reporting period to maintain parity with Medicare providers’
first meaningful use payment year.”
CMS notes that, in future years, the EHR reporting periods may be different for the Medicare and
Medicaid programs.
Certified EHR Technology
Federal Register page 44318
Background: The Secretary of Health and Human Services (the “Secretary”) has charged the ONC
with developing the criteria and mechanisms for certification of EHR technology. The ONC has issued
its final rule with details on the standards, implementation specifications, and certification criteria for
EHRs. The ONC has issued a separate rule related to the certification of health information
technology.
Final Rule: CMS will use the definition of certified EHR technology adopted by ONC.
Meaningful Use Criteria
Federal Register pages 44321 - 44380
CMS’ Proposal: CMS proposed to define meaningful use in three stages, with criteria becoming more
stringent over time. CMS proposed a list of specific criteria for Stage 1 (25 measures for EPs and 23
measures for eligible hospitals), all of which would have been required in order to qualify as
meaningful users.
Final Rule: CMS is adopting its phased approach to defining meaningful use. CMS anticipates at
least three stages of criteria, increasing in stringency. The Stage 1 criteria are the requirements for EPs
and eligible hospitals to qualify for incentive payments in their first payment year, whichever year that
may be. Stage 1 focuses on capturing information via certified EHR and using that information to
8
inform decision-making, track patient conditions, and coordinate care. Future stages will build on the
Stage 1 criteria to promote the electronic exchange of information and improvements in quality, safety,
and health.
CMS is only detailing the Stage 1 criteria in this final rule. The additional stages will be addressed in
future rulemaking. CMS plans to update the meaningful use criteria on a biennial basis, with the Stage
2 criteria by the end of 2011 and the Stage 3 criteria by the end of 2013. The new stages will build on
previously established stages and EPs; eligible hospitals and CAHs will be required to meet the criteria
of these new stages to qualify for the EHR incentives and avoid Medicare payment penalties. The
following table illustrates how CMS intends to implement the stages of meaningful use, depending
upon a provider’s first payment year:
Payment Year:
First Payment
Year: 2011 2012 2013 2014 2015
2011 Stage 1 Stage 1 Stage 2 Stage 2 TBD
2012 Stage 1 Stage 1 Stage 2 TBD
2013 Stage 1 Stage 1 TBD
2014 Stage 1 TBD
2015 TBD
Based on the above chart, eligible hospitals and EPs that qualify for their first payment in 2011, 2012,
or 2013 will be held to the Stage 1 criteria for their first and second payment years. CMS has not
determined what its criteria will be in 2015.
In response to comments, CMS has divided its Stage 1 requirements into two groups: a set of core
requirements (15 for EPs and 14 for eligible hospitals) and 10 menu requirements. Eligible hospitals
and EPs must meet all of their applicable core measure requirements and then may choose five of the
10 menu measures, with some restrictions and exceptions.
If it is impossible for an EP or eligible hospital to meet a specific measure, they will be excluded from
that requirement. If the excluded measure is one of the menu measures, the exclusion reduces the
number of measures that the provider must meet. In addition, three of the menu measures are
considered to be public health objectives. Eligible hospitals and EPs must choose at least one public
health measure from the menu.
The matrix on the following four pages lists the core and menu measures, their objectives, the
measurement standards, and the exception/exclusion criteria.
9
Stage 1 Meaningful Use Criteria for Eligible Hospitals and Professionals
Core Measures
EHR
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dic
atio
n t
hat
th
e p
atie
nt
has
no
kn
ow
n m
ed
icat
ion
all
erg
ies)
reco
rde
d a
s st
ruct
ure
d d
ata
in t
he
ir
me
dic
atio
n a
lle
rgy
list
.
Nu
mb
er
of
un
iqu
e p
atie
nts
ad
mit
ted
to
an e
ligi
ble
ho
spit
al’s
inp
atie
nt
or
em
erg
en
cy d
ep
artm
en
ts (
PO
S 21
or
23)
or
see
n b
y th
e E
P d
uri
ng
the
EH
R
rep
ort
ing
pe
rio
d.
No
80%
No
ne
No
ne
6C
OR
E
OB
JEC
TIV
EA
ll
Rec
ord
Dem
og
rap
hic
s (
pre
ferr
ed
lan
gu
ag
e, g
end
er, r
ace
, eth
nic
ity,
da
te
of
bir
th, d
ate
an
d p
relim
ina
ry c
au
se o
f
dea
th in
th
e ev
ent
of
mo
rta
lity
in t
he
elig
ible
ho
spit
al [
last
ob
ject
ive
is f
or
elig
ible
ho
spit
als
on
ly])
.
The
nu
mb
er
of
pat
ien
ts in
th
e
de
no
min
ato
r w
ho
hav
e a
ll t
he
ele
me
nts
of
de
mo
grap
hic
s (o
r a
spe
cifi
c e
xclu
sio
n if
th
e p
atie
nt
de
clin
ed
to
pro
vid
e o
ne
or
mo
re
ele
me
nts
or
if r
eco
rdin
g an
ele
me
nt
is
con
trar
y to
sta
te la
w)
reco
rde
d a
s
stru
ctu
red
dat
a.
Nu
mb
er
of
un
iqu
e p
atie
nts
ad
mit
ted
to
an e
ligi
ble
ho
spit
al’s
inp
atie
nt
or
em
erg
en
cy d
ep
artm
en
ts (
PO
S 21
or
23)
or
see
n b
y th
e E
P d
uri
ng
the
EH
R
rep
ort
ing
pe
rio
d.
No
50%
No
ne
No
ne
7C
OR
E
OB
JEC
TIV
EA
ll
Rec
ord
an
d C
ha
rt C
ha
ng
es in
Vit
al
Sig
ns
(h
eig
ht,
wei
gh
t, b
loo
d p
ress
ure
,
calc
ula
te a
nd
dis
pla
y B
MI,
an
d p
lot
an
d
dis
pla
y g
row
th c
ha
rts
for
child
ren
2 -
20
yea
rs, i
ncl
ud
ing
BM
I.
The
nu
mb
er
of
pat
ien
ts in
th
e
de
no
min
ato
r w
ho
hav
e a
t le
ast
on
e
en
try
of
the
ir h
eig
ht,
we
igh
t an
d b
loo
d
pre
ssu
re a
re r
eco
rde
d a
s st
ruct
ure
dat
a.
Nu
mb
er
of
un
iqu
e p
atie
nts
age
2 o
r
ove
r ad
mit
ted
to
an
eli
gib
le h
osp
ital
’s
inp
atie
nt
or
em
erg
en
cy d
ep
artm
en
ts
(PO
S 21
or
23)
or
see
n b
y th
e E
P d
uri
ng
the
EH
R r
ep
ort
ing
pe
rio
d.
Yes
50%
No
ne
An
y EP
wh
o e
ith
er
see
s
no
pat
ien
ts 2
ye
ars
or
old
er,
or
wh
o b
eli
eve
s
that
all
th
ree
vit
al s
ign
s
of
he
igh
t, w
eig
ht,
an
d
blo
od
pre
ssu
re o
f th
eir
pat
ien
ts h
ave
no
rele
van
ce t
o t
he
ir s
cop
e
of
pra
ctic
e.
8C
OR
E
OB
JEC
TIV
EA
llR
eco
rd S
mo
kin
g f
or
Pa
tien
ts 1
3 Y
ears
or
Old
er
The
nu
mb
er
of
pat
ien
ts in
th
e
de
no
min
ato
r w
ith
sm
oki
ng
stat
us
reco
rde
d a
s st
ruct
ure
d d
ata.
Nu
mb
er
of
un
iqu
e p
atie
nts
age
13
or
old
er
adm
itte
d t
o a
n e
ligi
ble
ho
spit
al’s
inp
atie
nt
or
em
erg
en
cy d
ep
artm
en
ts
(PO
S 21
or
23)
or
see
n b
y th
e E
P d
uri
ng
the
EH
R r
ep
ort
ing
pe
rio
d.
Yes
50%
An
y e
ligi
ble
ho
spit
al
that
ad
mit
s n
o p
atie
nts
13 y
ear
s o
r o
lde
r to
th
eir
inp
atie
nt
or
em
erg
en
cy
de
par
tme
nts
(P
OS
21 o
r
23).
An
y EP
wh
o s
ee
s n
o
pat
ien
ts 1
3 ye
ars
or
old
er.
10
Stage 1 Meaningful Use Criteria for Eligible Hospitals and Professionals
Core Measures (continued)
EHR
EHR
De
no
min
ato
r
Fun
ctio
nal
ity
EHR
Ob
ject
ive
EHR
Nu
me
rato
rD
en
om
inat
or
Lim
ite
d t
oTh
resh
old
Elig
ible
Ho
spit
alEP
Ob
ject
ive
Ob
ject
ive
Ap
pli
cab
leFu
nct
ion
alit
yfo
rfo
rP
atie
nt
Re
cord
sfo
rO
bje
ctiv
eO
bje
ctiv
e
Co
un
tTy
pe
ToO
bje
ctiv
eM
eas
uri
ng
Ob
ject
ive
Me
asu
rin
g O
bje
ctiv
eM
ain
tain
ed
in E
HR
Ach
ievi
ng
Ob
ject
ive
Exce
pti
on
Exce
pti
on
9C
OR
E
OB
JEC
TIV
EA
ll
Rep
ort
15
Ho
spit
al C
lin
ica
l Qu
ali
ty
Mea
sure
s (6
Am
bu
lato
ry in
th
e ca
se o
f
EPs)
to
CM
S (
in t
he
case
of
Med
ica
id
ho
spit
als
or
EPs,
qu
alit
y m
easu
res
wo
uld
be
rep
ort
ed t
o t
he
sta
te)
No
ne
No
ne
Yes
For
2011
, an
eli
gib
le h
osp
ital
or
EP
wo
uld
pro
vid
e t
he
agg
rega
te le
vel d
ata
for
the
nu
me
rato
r, d
en
om
inat
or,
an
d
exc
lusi
on
s re
late
d t
o t
he
re
qu
ire
d
qu
alit
y m
eas
ure
s th
rou
gh a
tte
stat
ion
.
For
2012
, an
eli
gib
le h
osp
ital
or
EP
wo
uld
ele
ctro
nic
ally
su
bm
it t
he
se
me
asu
res.
No
ne
No
ne
10C
OR
E
OB
JEC
TIV
EA
ll
Imp
lem
ent
On
e C
lin
ica
l Dec
isio
n
Sup
po
rt R
ule
an
d H
ave
Ab
ilit
y to
Tra
ck
Co
mp
lia
nce
wit
h R
ule
(fo
r el
igib
le
ho
spit
als
, th
e ru
le m
ust
be
rel
ate
d t
o a
hig
h c
linic
al p
rio
rity
; fo
r EP
s, t
he
rule
mu
st b
e re
leva
nt
to s
pec
ialt
y fo
r EP
s)
No
ne
No
ne
N/A
Elig
ible
ho
spit
al o
r EP
mu
st im
ple
me
nt
on
e c
lin
ical
de
cisi
on
su
pp
ort
ru
le.
No
ne
No
ne
11C
OR
E
OB
JEC
TIV
EA
ll
Pro
vid
e P
ati
ents
wit
h a
n E
lect
ron
ic
Co
py
of
thei
r H
ealt
h In
form
ati
on
Up
on
Req
ues
t (m
ust
incl
ud
e d
iag
no
stic
tes
t
resu
lts,
pro
ble
m li
st, m
edic
ati
on
list
s,
med
ica
tio
n a
llerg
ies,
an
d d
isch
arg
e
sum
ma
ry, p
roce
du
res
[la
st o
bje
ctiv
e is
for
elig
ible
ho
spit
als
on
ly])
The
nu
mb
er
of
pat
ien
ts in
th
e
de
no
min
ato
r w
ho
re
ceiv
e a
n e
lect
ron
ic
cop
y o
f th
eir
ele
ctro
nic
he
alth
info
rmat
ion
wit
hin
th
ree
bu
sin
ess
day
s.
The
nu
mb
er
of
pat
ien
ts o
f th
e e
ligi
ble
ho
spit
al’s
inp
atie
nt
or
em
erg
en
cy
de
par
tme
nts
(P
OS
21 o
r 23
) o
r EP
wh
o
req
ue
st a
n e
lect
ron
ic c
op
y o
f th
eir
ele
ctro
nic
he
alth
info
rmat
ion
fo
ur
bu
sin
ess
day
s p
rio
r to
th
e e
nd
of
the
EHR
re
po
rtin
g p
eri
od
.
Yes
50%
12C
OR
E
OB
JEC
TIV
EA
ll
Ca
pa
bil
ity
to E
lect
ron
ica
lly
Exch
an
ge
Key
Cli
nic
al I
nfo
rma
tio
n A
mo
ng
Pro
vid
ers
of
Ca
re a
nd
Pa
tien
t
Au
tho
rize
d E
nti
ties
(fo
r ex
am
ple
,
pro
ble
m li
st, m
edic
ati
on
list
, med
ica
tio
n
alle
rgie
s, a
nd
dia
gn
ost
ic t
est
resu
lts)
No
ne
No
ne
N/A
Elig
ible
ho
spit
al o
r EP
mu
st p
erf
orm
at
leas
t o
ne
te
st w
ith
an
oth
er
en
tity
of
the
cap
acit
y to
ele
ctro
nic
ally
exc
han
ge
key
clin
ical
info
rmat
ion
. Th
e t
est
mu
st
incl
ud
e t
he
tra
nsf
er
of
eit
he
r ac
tual
or
“du
mm
y” d
ata
to t
he
ch
ose
n o
the
r
en
tity
.
No
ne
No
ne
13C
OR
E
OB
JEC
TIV
EA
ll
Pro
tect
Ele
ctro
nic
Hea
lth
Info
rma
tio
n
(pro
tect
info
rma
tio
n c
rea
ted
or
ma
inta
ined
by
the
cert
ifie
d E
HR
tech
no
log
y th
rou
gh
th
e
imp
lem
enta
tio
n o
f a
pp
rop
ria
te
tech
nic
al c
ap
ab
iliti
es)
No
ne
No
ne
N/A
Elig
ible
ho
spit
al o
r EP
mu
st c
on
du
ct o
r
revi
ew
a s
ecu
rity
ris
k an
alys
is in
acco
rdan
ce w
ith
th
e r
eq
uir
em
en
ts
un
de
r 45
CFR
164
.308
(a)
(1)
and
imp
lem
en
t se
curi
ty u
pd
ate
s as
ne
cess
ary
and
co
rre
ct id
en
tifi
ed
secu
rity
de
fici
en
cie
s as
par
t o
f it
s ri
sk
man
age
me
nt
pro
cess
.
No
ne
No
ne
14C
OR
E
OB
JEC
TIV
E
Ho
spit
als
On
ly
Pro
vid
e P
ati
ents
wit
h a
n E
lect
ron
ic
Co
py
of
thei
r D
isch
arg
e In
stru
ctio
ns
(a
t
the
tim
e o
f d
isch
arg
e)
The
nu
mb
er
of
pat
ien
ts in
th
e
de
no
min
ato
r w
ho
are
pro
vid
ed
an
ele
ctro
nic
co
py
of
dis
char
ge
inst
ruct
ion
s.
Nu
mb
er
of
pat
ien
ts d
isch
arge
d f
rom
an
eli
gib
le h
osp
ital
’s in
pat
ien
t o
r
em
erg
en
cy d
ep
artm
en
ts (
PO
S 21
or
23)
wh
o r
eq
ue
st a
n e
lect
ron
ic c
op
y o
f th
eir
dis
char
ge in
stru
ctio
ns
and
pro
ced
ure
s
du
rin
g th
e E
HR
re
po
rtin
g p
eri
od
.
Yes
50%
An
y e
ligi
ble
ho
spit
al
that
has
no
re
qu
est
s
fro
m p
atie
nts
or
the
ir
age
nts
fo
r an
ele
ctro
nic
cop
y o
f th
e d
isch
arge
inst
ruct
ion
s d
uri
ng
the
EHR
re
po
rtin
g p
eri
od
.
N/A
14C
OR
E
OB
JEC
TIV
EEP
s O
nly
Gen
era
te a
nd
Tra
nsm
it P
erm
issi
ble
Pre
scri
pti
on
s El
ectr
on
ica
lly
(eR
x)
The
nu
mb
er
of
pre
scri
pti
on
s in
th
e
de
no
min
ato
r ge
ne
rate
d a
nd
tran
smit
ted
ele
ctro
nic
ally
.
Nu
mb
er
of
pre
scri
pti
on
s w
ritt
en
fo
r
dru
gs r
eq
uir
ing
a p
resc
rip
tio
n in
ord
er
to b
e d
isp
en
sed
oth
er
than
co
ntr
oll
ed
sub
stan
ces
du
rin
g th
e E
HR
re
po
rtin
g
pe
rio
d.
Yes
40%
N/A
An
y EP
wh
o w
rite
s fe
we
r
than
100
pre
scri
pti
on
s
du
rin
g th
e E
HR
re
po
rtin
g
pe
rio
d.
15C
OR
E
OB
JEC
TIV
EEP
s O
nly
Pro
vid
e C
lin
ica
l Su
mm
ari
es f
or
Pa
tien
ts
for
Each
Off
ice
Vis
it
Nu
mb
er
of
pat
ien
ts in
th
e d
en
om
inat
or
wh
o a
re p
rovi
de
d a
cli
nic
al s
um
mar
y o
f
the
ir v
isit
wit
hin
3 b
usi
ne
ss d
ays.
Nu
mb
er
of
un
iqu
e p
atie
nts
se
en
by
the
EP f
or
an o
ffic
e d
uri
ng
the
EH
R
rep
ort
ing
pe
rio
d.
Yes
50%
N/A
An
y EP
wh
o h
as n
o o
ffic
e
visi
ts d
uri
ng
the
EH
R
rep
ort
ing
pe
rio
d.
An
y e
ligi
ble
ho
spit
al o
r EP
th
at h
as n
o r
eq
ue
sts
fro
m p
atie
nts
or
the
ir a
gen
ts f
or
an e
lect
ron
ic c
op
y
of
pat
ien
t h
eal
th in
form
atio
n d
uri
ng
the
EH
R
rep
ort
ing
pe
rio
d.
11
Stage 1 Meaningful Use Criteria for Eligible Hospitals and Professionals
Menu Measures
EHR
EHR
De
no
min
ato
r
Fun
ctio
nal
ity
EHR
Ob
ject
ive
EHR
Nu
me
rato
rD
en
om
inat
or
Lim
ite
d t
oTh
resh
old
Elig
ible
Ho
spit
alEP
Ob
ject
ive
Ob
ject
ive
Ap
pli
cab
leFu
nct
ion
alit
yfo
rfo
rP
atie
nt
Re
cord
sfo
rO
bje
ctiv
eO
bje
ctiv
e
Co
un
tTy
pe
ToO
bje
ctiv
eM
eas
uri
ng
Ob
ject
ive
Me
asu
rin
g O
bje
ctiv
eM
ain
tain
ed
in E
HR
Ach
ievi
ng
Ob
ject
ive
Exce
pti
on
Exce
pti
on
1M
ENU
OB
JEC
TIV
EA
llIm
ple
men
t D
rug
-Fo
rmu
lary
Ch
ecks
No
ne
No
ne
N/A
Elig
ible
ho
spit
al o
r EP
has
en
able
d t
his
fun
ctio
nal
ity
and
has
acc
ess
to
at
leas
t
on
e in
tern
al o
r e
xte
rnal
fo
rmu
lary
fo
r
the
en
tire
EH
R r
ep
ort
ing
pe
rio
d.
No
ne
An
y EP
wh
o w
rite
s fe
we
r
than
100
pre
scri
pti
on
s
du
rin
g th
e E
HR
re
po
rtin
g
pe
rio
d.
2M
ENU
OB
JEC
TIV
EA
llIn
corp
ora
te C
lin
ica
l La
b-T
est
Res
ult
s
into
EH
R a
s St
ruct
ure
d D
ata
The
nu
mb
er
of
lab
te
st r
esu
lts
wh
ose
resu
lts
are
exp
ress
ed
in a
po
siti
ve o
r
ne
gati
ve a
ffir
mat
ion
or
as a
nu
mb
er
wh
ich
are
inco
rpo
rate
d a
s st
ruct
ure
d
dat
a.
Nu
mb
er
of
lab
te
sts
ord
ere
d d
uri
ng
the
EHR
re
po
rtin
g p
eri
od
by
the
au
tho
rize
d
pro
vid
ers
of
the
eli
gib
le h
osp
ital
or
pat
ien
ts a
dm
itte
d t
o a
n e
ligi
ble
ho
spit
al’s
inp
atie
nt
or
em
erg
en
cy
de
par
tme
nts
(P
OS
21 &
23)
or
EP w
ho
se
resu
lts
are
exp
ress
ed
in a
po
siti
ve o
r
ne
gati
ve a
ffir
mat
ion
or
as a
nu
mb
er.
Yes
40%
No
ne
An
EP
wh
o o
rde
rs n
o la
b
test
s w
ho
se r
esu
lts
are
eit
he
r in
a
po
siti
ve/n
ega
tive
or
nu
me
ric
form
at d
uri
ng
the
EH
R r
ep
ort
ing
pe
rio
d.
3M
ENU
OB
JEC
TIV
EA
ll
Gen
era
te L
ists
of
Pa
tien
ts b
y Sp
ecif
ic
Co
nd
itio
ns
to
use
fo
r q
ua
lity
imp
rove
men
t, r
edu
ctio
n o
f d
isp
ari
ties
,
rese
arc
h, o
r o
utr
each
No
ne
No
ne
N/A
Ge
ne
rate
at
leas
t o
ne
re
po
rt li
stin
g
pat
ien
ts o
f th
e e
ligi
ble
ho
spit
al o
r EP
wit
h a
sp
eci
fic
con
dit
ion
.
No
ne
No
ne
4M
ENU
OB
JEC
TIV
EA
ll
Use
Cer
tifi
ed E
HR
Tec
hn
olo
gy
to
Iden
tify
Pa
tien
t-Sp
ecif
ic E
du
cati
on
Res
ou
rces
an
d p
rovi
de
tho
se r
eso
urc
es
to t
he
pa
tien
t if
ap
pro
pri
ate
Nu
mb
er
of
pat
ien
ts in
th
e d
en
om
inat
or
wh
o a
re p
rovi
de
d p
atie
nt
ed
uca
tio
n
spe
cifi
c re
sou
rce
s.
Nu
mb
er
of
un
iqu
e p
atie
nts
ad
mit
ted
to
an e
ligi
ble
ho
spit
al’s
inp
atie
nt
or
em
erg
en
cy d
ep
artm
en
ts (
PO
S 21
or
23)
or
see
n b
y th
e E
P d
uri
ng
the
EH
R
rep
ort
ing
pe
rio
d.
No
10%
No
ne
No
ne
5M
ENU
OB
JEC
TIV
EA
ll
Per
form
Med
ica
tio
n R
eco
nci
lia
tio
n
wh
en a
pa
tien
t is
rec
eive
d f
rom
an
oth
er
sett
ing
or
pro
vid
er o
f ca
re o
r th
e el
igib
le
ho
spit
al,
or
EP b
elie
ves
the
enco
un
ter
is
rele
van
t
The
nu
mb
er
of
tran
siti
on
s o
f ca
re in
th
e
de
no
min
ato
r w
he
re m
ed
icat
ion
reco
nci
liat
ion
was
pe
rfo
rme
d.
Nu
mb
er
of
tran
siti
on
s o
f ca
re d
uri
ng
the
EH
R r
ep
ort
ing
pe
rio
d f
or
wh
ich
th
e
eli
gib
le h
osp
ital
’s in
pat
ien
t o
r
em
erg
en
cy d
ep
artm
en
ts (
PO
S 21
to
23)
or
EP w
as t
he
re
ceiv
ing
par
ty o
f th
e
tran
siti
on
.
Yes
50%
No
ne
An
EP
wh
o w
as n
ot
the
reci
pie
nt
of
any
tran
siti
on
s o
f ca
re d
uri
ng
the
EH
R r
ep
ort
ing
pe
rio
d.
6M
ENU
OB
JEC
TIV
EA
ll
Pro
vid
e Su
mm
ary
Ca
re R
eco
rd f
or
Each
Tra
nsi
tio
n o
f C
are
or
Ref
erra
l w
hen
an
elig
ible
ho
spit
al o
r EP
tra
nsi
tio
ns
thei
r
pa
tien
t to
an
oth
er s
etti
ng
or
pro
vid
er o
f
care
or
refe
rs t
hei
r p
ati
ent
to a
no
ther
pro
vid
er o
f ca
re
The
nu
mb
er
of
tran
siti
on
s o
f ca
re a
nd
refe
rral
s in
th
e d
en
om
inat
or
wh
ere
a
sum
mar
y o
f ca
re r
eco
rd w
as p
rovi
de
d.
Nu
mb
er
of
tran
siti
on
s o
f ca
re a
nd
refe
rral
s d
uri
ng
the
EH
R r
ep
ort
ing
pe
rio
d f
or
wh
ich
th
e e
ligi
ble
ho
spit
al’s
inp
atie
nt
or
em
erg
en
cy d
ep
artm
en
ts
(PO
S 21
to
23)
or
EP w
as t
he
tran
sfe
rrin
g o
r re
ferr
ing
pro
vid
er.
Yes
50%
No
ne
An
EP
wh
o n
eit
he
r
tran
sfe
rs a
pat
ien
t to
ano
the
r se
ttin
g n
or
refe
rs a
pat
ien
t to
ano
the
r p
rovi
de
r d
uri
ng
the
EH
R r
ep
ort
ing
pe
rio
d.
7M
ENU
OB
JEC
TIV
EA
ll
Ca
pa
bil
ity
to S
ub
mit
Ele
ctro
nic
Da
ta t
o
Imm
un
iza
tio
n R
egis
trie
s o
r
Imm
un
iza
tio
n In
form
ati
on
Sys
tem
s
an
d A
ctu
al S
ub
mis
sio
n A
cco
rdin
g t
o
Ap
pli
cab
le L
aw
an
d P
ract
ice
No
ne
No
ne
N/A
Pe
rfo
rme
d a
t le
ast
on
e t
est
of
cert
ifie
d
EHR
te
chn
olo
gy's
cap
acit
y to
su
bm
it
ele
ctro
nic
dat
a to
imm
un
izat
ion
regi
stri
es
and
fo
llo
w u
p s
ub
mis
sio
n if
the
te
st is
su
cce
ssfu
l (u
nle
ss n
on
e o
f
the
imm
un
izat
ion
re
gist
rie
s to
wh
ich
the
eli
gib
le h
osp
ital
or
EP s
ub
mit
s su
ch
info
rmat
ion
hav
e t
he
cap
acit
y to
rece
ive
th
e in
form
atio
n e
lect
ron
ical
ly).
The
te
st m
ust
incl
ud
e t
he
tra
nsf
er
of
eit
he
r ac
tual
or
“du
mm
y” d
ata
to t
he
cho
sen
pu
bli
c h
eal
th a
gen
cy.
An
eli
gib
le h
osp
ital
or
EP t
hat
ad
min
iste
rs n
o
imm
un
izat
ion
s d
uri
ng
the
EH
R r
ep
ort
ing
pe
rio
d o
r
wh
ere
no
imm
un
izat
ion
re
gist
ry h
as t
he
cap
acit
y
to r
ece
ive
th
e in
form
atio
n e
lect
ron
ical
ly.
12
Stage 1 Meaningful Use Criteria for Eligible Hospitals and Professionals
Menu Measures (continued)
EHR
EHR
De
no
min
ato
r
Fun
ctio
nal
ity
EHR
Ob
ject
ive
EHR
Nu
me
rato
rD
en
om
inat
or
Lim
ite
d t
oTh
resh
old
Elig
ible
Ho
spit
alEP
Ob
ject
ive
Ob
ject
ive
Ap
pli
cab
leFu
nct
ion
alit
yfo
rfo
rP
atie
nt
Re
cord
sfo
rO
bje
ctiv
eO
bje
ctiv
e
Co
un
tTy
pe
ToO
bje
ctiv
eM
eas
uri
ng
Ob
ject
ive
Me
asu
rin
g O
bje
ctiv
eM
ain
tain
ed
in E
HR
Ach
ievi
ng
Ob
ject
ive
Exce
pti
on
Exce
pti
on
8M
ENU
OB
JEC
TIV
EA
ll
Ca
pa
bil
ity
to S
ub
mit
Ele
ctro
nic
Syn
dro
mic
Su
rvei
lla
nce
Da
ta t
o P
ub
lic
Hea
lth
Ag
enci
es a
nd
Act
ua
l Su
bm
issi
on
Acc
ord
ing
to
Ap
pli
cab
le L
aw
an
d
Pra
ctic
e
No
ne
No
ne
N/A
Pe
rfo
rme
d a
t le
ast
on
e t
est
of
cert
ifie
d
EHR
te
chn
olo
gy's
cap
acit
y to
pro
vid
e
ele
ctro
nic
syn
dro
mic
su
rve
illa
nce
dat
a
to p
ub
lic
he
alth
age
nci
es
and
fo
llo
w-u
p
sub
mis
sio
n if
th
e t
est
is s
ucc
ess
ful
(un
less
no
ne
of
the
pu
bli
c h
eal
th
age
nci
es
to w
hic
h t
he
eli
gib
le h
osp
ital
or
EP s
ub
mit
s in
form
atio
n h
ave
th
e
cap
acit
y to
re
ceiv
e t
he
info
rmat
ion
ele
ctro
nic
ally
). T
he
te
st m
ust
incl
ud
e
the
tra
nsf
er
of
eit
he
r ac
tual
or
“du
mm
y” d
ata
to t
he
ch
ose
n p
ub
lic
he
alth
age
ncy
.
No
pu
bli
c h
eal
th a
gen
cy
to w
hic
h t
he
eli
gib
le
ho
spit
al s
ub
mit
s
info
rmat
ion
has
th
e
cap
acit
y to
re
ceiv
e t
he
info
rmat
ion
ele
ctro
nic
ally
.
An
EP
wh
o d
oe
s n
ot
coll
ect
an
y re
po
rtab
le
syn
dro
mic
info
rmat
ion
on
th
eir
pat
ien
ts d
uri
ng
the
EH
R r
ep
ort
ing
pe
rio
d
or
do
es
no
t su
bm
it s
uch
info
rmat
ion
to
an
y
pu
bli
c h
eal
th a
gen
cy
that
has
th
e c
apac
ity
to
rece
ive
th
e in
form
atio
n
ele
ctro
nic
ally
.
9M
ENU
OB
JEC
TIV
E
Ho
spit
als
On
ly
Rec
ord
Ad
van
ce D
irec
tive
s fo
r P
ati
ents
65 Y
ears
or
Old
er
The
nu
mb
er
of
pat
ien
ts in
th
e
de
no
min
ato
r w
ith
an
ind
icat
ion
of
an
adva
nce
d d
ire
ctiv
e e
nte
red
usi
ng
stru
ctu
red
dat
a.
Nu
mb
er
of
un
iqu
e p
atie
nts
age
65
or
old
er
adm
itte
d t
o a
n e
ligi
ble
ho
spit
al’s
inp
atie
nt
de
par
tme
nt
(PO
S 21
) d
uri
ng
the
EH
R r
ep
ort
ing
pe
rio
d.
Yes
50%
An
eli
gib
le h
osp
ital
th
at
adm
its
no
pat
ien
ts a
ge
65 y
ear
s o
ld o
r o
lde
r
du
rin
g th
e E
HR
re
po
rtin
g
pe
rio
d.
N/A
10M
ENU
OB
JEC
TIV
E
Ho
spit
als
On
ly
Ca
pa
bil
ity
to S
ub
mit
Ele
ctro
nic
Da
ta o
n
Rep
ort
ab
le L
ab
Res
ult
s to
Pu
bli
c H
ealt
h
Ag
enci
es a
nd
Act
ua
l Su
bm
issi
on
Acc
ord
ing
to
Ap
pli
cab
le L
aw
an
d
Pra
ctic
e (
as
req
uir
ed b
y st
ate
or
loca
l
law
)
No
ne
No
ne
N/A
Pe
rfo
rme
d a
t le
ast
on
e t
est
of
cert
ifie
d
EHR
te
chn
olo
gy’s
cap
acit
y to
pro
vid
e
ele
ctro
nic
su
bm
issi
on
of
rep
ort
able
lab
resu
lts
to p
ub
lic
he
alth
age
nci
es
and
foll
ow
-up
su
bm
issi
on
if t
he
te
st is
succ
ess
ful (
un
less
no
ne
of
the
pu
bli
c
he
alth
age
nci
es
to w
hic
h a
n e
ligi
ble
ho
spit
al o
r EP
su
bm
its
such
info
rmat
ion
hav
e t
he
cap
acit
y to
re
ceiv
e t
he
info
rmat
ion
ele
ctro
nic
ally
). T
he
te
st
mu
st in
clu
de
th
e t
ran
sfe
r o
f e
ith
er
actu
al o
r “d
um
my”
dat
a to
th
e c
ho
sen
pu
bli
c h
eal
th a
gen
cy.
No
pu
bli
c h
eal
th a
gen
cy
to w
hic
h t
he
eli
gib
le
ho
spit
al s
ub
mit
s su
ch
info
rmat
ion
has
th
e
cap
acit
y to
re
ceiv
e t
he
info
rmat
ion
ele
ctro
nic
ally
.
N/A
9M
ENU
OB
JEC
TIV
EEP
s O
nly
Sen
d R
emin
der
s to
Pa
tien
ts P
er P
ati
ent
Pre
fere
nce
fo
r P
reve
nti
ve/F
oll
ow
-up
Ca
re
The
nu
mb
er
of
pat
ien
ts in
th
e
de
no
min
ato
r w
ho
we
re s
en
t th
e
app
rop
riat
e r
em
ind
er.
Nu
mb
er
of
un
iqu
e p
atie
nts
65
year
s o
r
old
er
or
5 ye
ars
or
you
nge
r se
en
by
the
EP d
uri
ng
the
EH
R r
ep
ort
ing
pe
rio
d.
Yes
20%
N/A
An
EP
wh
o h
as n
o
pat
ien
ts 6
5 ye
ars
old
or
old
er
or
5 ye
ars
old
or
you
nge
r w
ith
re
cord
s
mai
nta
ine
d u
sin
g
cert
ifie
d E
HR
tech
no
logy
.
10M
ENU
OB
JEC
TIV
EEP
s O
nly
Pro
vid
e P
ati
ents
wit
h T
imel
y El
ectr
on
ic
Acc
ess
to T
hei
r H
ealt
h In
form
ati
on
Wit
hin
4 B
usi
nes
s D
ays
of
the
Info
rma
tio
n B
ein
g A
vail
ab
le t
o t
he
EP
(in
clu
din
g la
b r
esu
lts,
pro
ble
m li
st,
med
ica
tio
n li
sts,
an
d a
llerg
ies)
The
nu
mb
er
of
pat
ien
ts in
th
e
de
no
min
ato
r w
ho
hav
e t
ime
ly
(ava
ilab
le t
o t
he
pat
ien
t w
ith
in 4
bu
sin
ess
day
s o
f b
ein
g u
pd
ate
d in
th
e
cert
ifie
d E
HR
te
chn
olo
gy)
ele
ctro
nic
acce
ss t
o t
he
ir h
eal
th in
form
atio
n
on
lin
e.
Nu
mb
er
of
un
iqu
e p
atie
nts
se
en
by
the
EP d
uri
ng
the
EH
R r
ep
ort
ing
pe
rio
d.
No
10%
su
bje
ct t
o E
P's
dis
cre
tio
n t
o
wit
hh
old
ce
rtai
n in
form
atio
n.
N/A
An
y EP
th
at n
eit
he
r
ord
ers
no
r cr
eat
es
any
of
the
info
rmat
ion
list
ed
at
45 C
FR 1
70.3
04(g
) d
uri
ng
the
EH
R r
ep
ort
ing
pe
rio
d.
13
For eligible hospitals, the Stage 1 measures apply to services for inpatients and, in most cases, patients
admitted to an emergency department – as determined by POS codes 21 and 23. CMS has received
numerous comments and requests for clarification on which patients seen in the emergency department
are to be included in these meaningful use criteria. CMS has promised to provide further guidance in
future communications. Patients seen in other outpatient settings are not included in the percentage of
patients measure for Stage 1. CMS is considering whether to expand the applicability of the
measurements to the outpatient setting for Stages 2 and/or 3.
For EPs working at multiple locations, 50 percent of their total patient encounters must take place at
locations where certified EHR technology is available. All applicable meaningful use measures should
be based only on encounters that occur at those service locations where certified EHR technology is
available.
The rule requires that EPs and eligible hospitals demonstrate meaningful use via an electronically
submitted attestation, occurring after the completion of the EHR reporting period for any payment year.
The attestation would include identification of the certified EHR technology in use, reporting of the
objective measurements, and reporting of clinical quality measures. Eligible hospitals and EPs will be
required to use certified EHR technology to meet the specified objectives and report the specific
measures to CMS – this includes both the HIT functionality measures and the reporting of clinical
quality measures. (See the following section “Quality Measure Reporting” for details.)
Common Definition of Meaningful Use under Medicare and Medicaid
Federal Register pages 44324 - 44325
CMS’ Proposal: “We believe that given the strong level of interaction on meaningful use encouraged
by the HITECH Act, there would need to be a compelling reason to create separate definitions for
Medicare and Medicaid. We have found no such reasons for disparate definitions in our internal or
external discussions. . . .Therefore, we propose to create a common definition of meaningful use that
would serve as the definition for providers participating in the Medicare FFS and MA EHR incentive
program, and the minimum standard for EPs and eligible hospitals participating in the Medicaid EHR
incentive program. We clarify that under Medicaid this common definition would be the minimum
standard.”
While the Medicare definition would be the minimum standard, CMS also proposed to allow states to
add additional objectives to the definition of meaningful use or modify how the existing objectives are
measured.
Final Rule: CMS is adopting its proposal as final with the following clarification: “. . . eligible
hospitals who are meaningful users under the Medicare EHR incentive payment program are deemed
as meaningful users under the Medicaid EHR incentive payment program, and need not meet
additional criteria imposed by the State. While this is not a new requirement, it was not previously
listed in regulations.”
CMS is also revising its stance on how much the states can alter the meaningful use objectives for
Stage 1: “. . . for Stage 1, (we) will only entertain States’ requests to tailor the Stage 1 meaningful use
definition as it pertains specifically to public health objectives and data registries.” This means that,
14
while states may tailor the Stage 1 definitions, those EPs and eligible hospitals that qualify under the
Medicare criteria cannot be held to any stricter definitions.
Medicaid Exception for the First Year of Participation
Federal Register pages 44503 - 44505
The HITECH Act gives states some latitude in applying the meaningful use criteria for the first
payment year. Eligible hospitals and EPs can qualify for Medicaid incentive payments in the first
payment year by adopting, implementing, or upgrading (AIU) to certified EHR technology.
CMS’ Proposal: CMS proposed that eligible hospitals and EPs attest to having adopted, implemented,
or upgraded their certified EHR technology using the following criteria:
Evidence of adoption requires that the provider demonstrate actual installation of certified EHR
technology (as opposed to efforts to install);
Evidence of implementation requires that the provider has started using the certified EHR
technology in their clinical practice. Implementation activities include staff training, data entry
of patient information, or establishing data exchange agreements with other healthcare entities;
and
Evidence of upgrade requires the provider demonstrate certified EHR technology functionality
expansion, such as an addition of clinical decision support, eRx, or CPOE.
The states would be responsible for verifying the attestations of eligible hospitals and EPs.
Final Rule: CMS is adopting its proposed criteria as final with the following clarification: “. . . we are
clarifying that the final definition of adopt, implement or upgrade is inclusive of providers’ acquisition,
such as a purchase, of a certified EHR.”
VI. CLINICAL QUALITY MEASURE (CQM) REPORTING
EPs and eligible hospitals must successfully report clinical quality measures in the form and manner
specified by CMS to qualify as Stage 1 meaningful users of EHR technology.
Reporting Requirements
Federal Register pages 44380 - 44382
CMS’ Proposal: For the 2011 EHR reporting period, CMS proposed that providers (EPs and eligible
hospitals) use an attestation methodology to submit summarized data, generated using certified EHR
technology, on the required clinical quality measures (numerator, denominator, and exclusions). In
addition, CMS proposed to require that EPs and eligible hospitals attest to the accuracy and
completeness of the numerators and denominators for each required clinical quality measure.
Beginning in 2012, EPs and eligible hospitals would be required to submit patient-level data, via the
EHR, for calculation of quality measures.
Final Rule: CMS has adopted its proposal as final. The reporting of quality measures for the EHR
incentive program are in addition to the reporting requirements under other federal and state programs
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(e.g. the Medicare Reporting Hospital Quality Data for Annual Payment Update (RHQDAPU)
program). The proposed quality measures would also apply to the Medicaid incentive program.
Hospital Clinical Quality Measures (CQM)
Federal Register pages 44411 - 44422
CMS’ Proposal: CMS originally proposed 35 clinical quality measures for eligible hospitals to submit
data on to meet the meaningful use requirements under Stage 1. Some of the proposed measures are
currently reported under RHQDAPU and some were proposed for future Medicare reporting. Only
fifteen of the proposed measures have electronic specifications.
Final Rule: CMS has revised its proposal and is requiring only the fifteen e-specified measures for
reporting and meeting the CQM requirement for meaningful use. None of the final fifteen measures are
currently required for reporting under any other federal program, hence there are no duplicative
reporting requirements. CMS states its intent to align the EHR incentive program’s quality reporting
requirements with the RHQDAPU program.
The CMS CQM tables from the Federal Register are provided on the next three pages:
16
Clinical Quality Measures (CQM) for Electronic Submission by Eligible Hospitals for Stage 1
17
Clinical Quality Measures (CQM) for Electronic Submission by Eligible Hospitals for Stage 1
(continued)
18
Clinical Quality Measures (CQM) for Electronic Submission by Eligible Hospitals for Stage 1
(continued)
19
Physician Clinical Quality Measures
Federal Register pages 44386 - 44411
CMS’ Proposal: CMS proposed that, for Stage 1 meaningful use, EPs report on three core measures
and a set of measures specific to one of 15 individual specialty groups. CMS proposed that EPs be
required to report on all applicable cases for the core measures as well as each measure in one selected
specialty group. EPs would be required to select the same specialty group for both the first and second
EHR reporting year. EPs would be allowed to attest that none of the measures are applicable to their
specialty.
Final Rule: CMS has revised its proposed requirements such that all of the clinical quality measures
for EPs are e-specified. CMS will require all EPs to report on three core measures. Rather than
attesting to the applicability of some or all of the core measures, CMS states that a denominator of zero
is acceptable. The three core measures that EPs will be required to report are:
NQF 0013: Hypertension: Blood Pressure Management;
NQF 0028: Preventative Care and Screening Measure Pair: a. Tobacco Use Assessment b.
Tobacco Cessation Intervention; and
NQF0421/ PQRI 128: Adult Weight Screening and Follow-up.
If the denominator for one or more of the core measures is zero, EPs will be required to report results
for up to three alternate core measures:
NQF 0041/PQRI 110: Preventative Care and Screening: Influenza Immunization for Patients
≥50 Years Old;
NQF 0024: Weight Assessment and Counseling for Children and Adolescents; and
NQF 0038: Childhood Immunization Status.
“We believe this final set of core clinical quality measures provides EPs a greater opportunity for
successful reporting. The EP will not be excluded from reporting any core or alternate clinical quality
measure because the measure does not apply to the EPs scope of practice or patient population. The
expectation is that the EHR will automatically report on each core clinical quality measure, and when
one or more of the core measures has a denominator of zero then the alternate core measure(s) will be
reported.”
In addition to the three core measures, EPs must report on three additional clinical measures from a
menu provided by CMS (Table 6, pages 44398 – 44408 in the Federal Register). Even if the EP
reports zero denominators in all six of the core and alternate core measures, he/she must still report on
three additional clinical quality measures and will only be exempt from reporting of these measures if
he/she can attest that all of the CQMs in the final rule do not apply: “If all six of the clinical quality
measures in Table 7 have zeros for the denominators (this would imply that the EPs patient population
is not addressed by these measures), then the EP is still required to report on three additional clinical
measures of their choosing from Table 6 in this final rule. In regard to the three additional clinical
quality measures, if the EP reports zero values, then for the remaining clinical quality measures in
Table 6 (other than the core and alternate core measures) the EP will have to attest that all of the other
clinical quality measures calculated by the certified EHR technology have a value of zero in the
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denominator, if the EP is to be exempt from reporting any of the additional clinical quality measures
(other than the core and alternate core measures) in Table 6.”
VII. INCENTIVE PAYMENT CALCULATION
The HITECH Act provides for incentive payments for the meaningful use of certified EHR technology
under the Medicare and Medicaid programs. A provider must meet the definition of either eligible
professional or eligible hospital and satisfy the criteria for meaningful use for a payment year in order
to qualify for incentive payments.
Eligible hospitals (except cancer and children’s hospitals) may qualify for payments under both
programs. Cancer hospitals and children’s hospitals may only qualify for incentive payments under the
Medicaid program; EPs may participate in only one program and must designate which program they
choose.
Medicare Incentive Payments for Hospitals (excluding cancer hospitals, children’s hospitals, and
CAHs)
Federal Register pages 44450 - 44460
Final Rule: CMS has clarified its proposal for calculating incentive payments by correcting references
to Medicare cost report lines and specifying which cost reports will be used to determine interim and
final settled payments. Qualifying eligible hospitals will receive EHR incentive payments for up to
four consecutive years. The first possible payment year is FY2011, which begins on October 1, 2010.
The last payment year for which a hospital may qualify for incentive payments is FY2015, which
begins on October 1, 2014.
For each qualifying year, the incentive payment will be calculated as an initial amount multiplied by
the hospital’s Medicare share and a transition factor. The initial amount will be calculated as a base
amount ($2 million) plus a discharge-related amount ($200 per discharge for discharges between 1,150
and 23,000). The Medicare share will be calculated as the proportion of Medicare inpatient days to
total inpatient days, with an adjustment to reflect charity care. The transition factor decreases the
incentive payments over the four-year period. The formula can be represented as follows:
All data for calculating the Medicare incentive payment are to be taken from hospitals’ Medicare cost
reports, including the data for charity care charges, which is expected to be available on the new cost
report worksheet S-10, which is to be effective for cost reporting periods beginning on or after
February 1, 2010. CMS states that, if data on charity care is not available, data on uncompensated care
will be used. If neither of these two data elements is available, CMS will assume the ratio of charges
excluding charity care to total charges to be 1.
Incentive Payment =
{(Total Inpatient Bed Days) * [(Total Charges - Charity Care Charges) / Total Charges]}
Transition Factor = 100%, 75%, 50%, or 25% depending upon payment year
Medicare Share = Medicare Inpatients Bed Days
[$2 million + ($200 * # discharges between 1,150 & 23,000)] * Medicare Share *
Transition Factor
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Table 14 on page 44460 of the Federal Register (copy below) illustrates how the transition factors will
be applied based upon a hospital’s first qualifying year and how many years it has qualified.
Payment Year: 2011 2012 2013 2014 2015
2011 100% - - - -
2012 75% 100% - - -
2013 50% 75% 100% - -
2014 25% 50% 75% 75% -
2015 - 25% 50% 50% 50%
2016 - - 25% 25% 25%
First Qualifying Year:
The largest incentive payments will be paid to early adopters of meaningful EHR technology. Later
adopters will receive less incentive money in total. The maximum number of incentive payment years
for any hospital is four – eligible hospitals that qualify in 2011, 2012, or 2013 will be on track to
receive the maximum incentive payment.
For the Medicare program, the payment years are consecutive, i.e. if an eligible hospital qualifies as a
meaningful user under Stage 1 for two payment years, then fails to qualify under Stage 2 for the third
payment year, that year is still counted as one the four allowable payment years and the hospital will
not receive its maximum incentive payment. In this example, if the eligible hospital were to qualify in
the fourth payment year, it would be subject to the 25 percent transition factor and that would be its last
incentive payment.
Eligible hospitals that do not qualify as meaningful users by FY2015 will not receive any incentive
payments and will be subject to IPPS payment penalties as follows:
FY2015 = 33 1/3 percent of ¾ of applicable market basket (results in 25 percent reduction)
FY2016 = 66 2/3 percent of ¾ of applicable market basket (results in 50 percent reduction)
FY2017 = 100 percent of ¾ of applicable market basket (results in 75 percent reduction)
These payment penalties are in addition to any other market basket penalties the hospital may incur for
failing to meet the reporting requirements under RHQDAPU. By FY2017, hospitals that do not meet
both the RHQDAPU and the meaningful use requirements would not receive any market basket update
to their Medicare IPPS payments. The market basket reductions under the ACA will also apply.
CMS will direct the FIs/MACs to calculate and disburse the Medicare incentive payments, on an
interim basis, once the eligible hospital has demonstrated that it qualifies as a meaningful user. The
incentive payments will be based upon the prior year’s cost report and available PS&R data, and will be
subject to reconciliation upon final settlement of the appropriate Medicare cost report: “As a result of
the changes we are making to these proposed policies in response to the comments discussed in the
previous section, in this final rule we are adopting the following policies for employing data on the
eligible hospital’s Medicare fee-for-service and managed care inpatient bed days, total inpatient bed-
22
days, and charges for charity care from the hospital in making preliminary and final EHR incentive
payment determinations:
For purposes of determining preliminary incentive payments, we will employ data on the hospital’s
Medicare fee-for-service and managed care inpatient bed days, total inpatient bed-days, and
charges for charity care from a hospital’s most recently submitted 12-month cost report once the
hospital has qualified as a meaningful user.
For purposes of determining final incentive payments, we will employ the first 12-month cost
reporting period that begins after the start of the payment year, in order to settle payments on the
basis of the hospital’s Medicare fee-for-service and managed care inpatient bed days, total
inpatient bed-days, and charges for charity care data from that cost reporting period.”
Medicare Incentive Payments for CAHs
Federal Register pages 44460 - 44464
Final Rule: CMS is adopting as final its proposal for calculating Medicare incentive payments for
CAHs. Qualifying CAHs may receive incentive payments in up to four consecutive payment years,
beginning with cost reporting periods that start in FY2011. The year with a cost reporting period that
begins in FY2015 is the last payment year for which a qualifying CAH may receive incentive
payments. This means that CAHs that first qualify for incentive payments in FY2013 or later will not
qualify for four consecutive payments.
Since CAH payments are based upon actual costs, including capital costs, the HITECH Act and the
final rule allow for accelerated depreciation of the capital costs associated with implementation and
support of meaningful use. The accelerated depreciation/reimbursement of these capital costs only
applies to relevant and qualifying assets and may only be used for new purchases or the remaining, un-
depreciated portions of existing assets. CMS is clear in the final rule that non-depreciable costs, such
as labor and incidentals associated with the purchase and installation of certified EHR technology, are
not included in these incentive payments; those costs (if allowable) would be reimbursed at 101 percent
under the existing CAH reimbursement methodology.
Qualifying CAHs will receive prompt interim payments (subject to reconciliation) equal to the
reasonable depreciable cost of the asset multiplied by the CAH’s Medicare share. The Medicare share
for CAHs will be calculated in the same manner as for hospitals plus an additional 20 percentage points
(not to exceed a total Medicare share of 100 percent).
Eligible CAHs that do not qualify as meaningful users by FY2015 will not receive any incentive
payments and will be subject to reduced cost-based payments as follows:
FY2015: 100.66 percent of cost
FY2016: 100.33 percent of cost
FY2017 and thereafter: 100 percent of cost
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Medicare Incentive Payments for EPs
Federal Register pages 44442 - 44447
An EP that qualifies under both the Medicare and Medicaid EHR incentive programs must notify CMS,
upon registration, whether he/she elects Medicare or Medicaid incentive payments. Qualifying EPs
may switch payment programs only once prior to 2015.
Final Rule: CMS is adopting its proposals as final. Under the Medicare program, qualifying EPs can
receive up to five consecutive years of Medicare incentive payments. The incentive payments will be
equal to the lesser of 75 percent of the physician’s allowed Medicare charges for the payment year or a
specified maximum. Similar to the transition factor for hospitals, the maximum payment for qualifying
EPs decreases over time, depending upon the first qualifying year and number of years of payments.
An EP may assign his/her incentive payments to their employer or to an entity with which they have a
contractual arrangement. However, even when an EP reassigns their incentive payments, it is the EP
that must register for the program, attest to meaningful use status and be subject to Medicare payment
penalties if not a meaningful user by 2015.
CMS will make one consolidated annual payment to qualifying EPs in each payment year. The
following table illustrates how payments will be made to qualifying professionals based upon first
qualifying year and number of years – assuming the maximum payment in each year:
The maximum number of consecutive years for which a qualifying EP can receive incentive payments
is five; the maximum total incentive payment is $44,000. Qualifying EPs that practice predominantly
in health professional shortage areas (HPSAs) can receive an additional 10 percent in incentive funding
(up to a maximum of $48,400). CMS defines an EP as practicing predominantly in a HPSA when
he/she provides more than 50 percent of their Medicare-covered services in a HPSA.
Eligible EPs that do not qualify as meaningful users by FY2015 will not receive any incentive
payments and will be subject to reduced payments as follows:
CY 2011 CY 2012 CY 2013 CY 2014 CY 2015 and
Later
CY 2011 $ 18,000
CY 2012 $ 12,000 $ 18,000
CY 2013 $ 8,000 $ 12,000 $ 15,000
CY 2014 $ 4,000 $ 8,000 $ 12,000 $ 12,000
CY 2015 $ 2,000 $ 4,000 $ 8,000 $ 8,000
CY 2016 $ 2,000 $ 4,000 $ 4,000
Total $ 44,000 $ 44,000 $ 39,000 $ 24,000 $ 0
First Qualifying Year:
24
At the Secretary’s discretion, additional payment penalties of up to 5.0 percent may be applied in 2018
and later years if fewer than 75 percent of EPs are meaningful users. The Secretary may also grant a
hardship exception to individual EPs if the payment penalty would create a significant hardship.
NOTE: Per CMS, all Medicare providers will receive a payment reduction in 2015 if they are not
demonstrating meaningful use. EPs that have chosen to participate in the Medicaid EHR incentive
payment program and are not demonstrating meaningful use for that program by 2015 will receive a
Medicare fee-schedule reduction for all Medicare claims.
Medicaid Incentive Payments for Eligible Hospitals (including CAHs)
Federal Register pages 44497 - 44501
The HITECH Act mandates that the federal government provide matching funds to the States for
implementation of a Medicaid EHR incentive program. The matching funds are 90 percent of the
state’s costs of administering the program and 100 percent of the costs for incentive payments made to
providers.
The HITECH Act gives states some latitude to determine how many years of payments to make and
how those payments will be divided over the years. The limiting factors are: 1) total incentive
payments to a qualifying hospital may not exceed a predetermined maximum; 2) the minimum number
of years of payments is three and the maximum number is six; 3) the last year for a qualifying hospital
to first receive a Medicaid incentive payment is 2016; 4) the incentive payment amount for any one
year may not exceed 50 percent of the predetermined maximum; and 5) the incentive payment amount
for any two-year period may not exceed 90 percent of the predetermined maximum.
Final Rule: CMS is adopting its proposals as final, with some clarifications. The maximum payment
amount for any individual qualifying hospital will be calculated according to the Medicare payment
formula, using a Medicaid share in place of the Medicare share, assuming four years of payment at the
Medicare transition factors described above. The resulting four-year total is the maximum amount
available for the state to disburse to the qualifying hospital. States may opt to disburse less than the
maximum amount, but not more.
When calculating the maximum amount, each state may use either the same Medicare cost report data
sources as for the Medicare calculation or they may use alternate data sources, such as state Medicaid
cost reports. Any alternate data sources must be auditable. For the discharge-related payment portion,
states are directed to use the average volume growth rate for the past three years to project volume
growth over the four years in the maximum calculation. CMS is clarifying that dually eligible
individuals are excluded from the numerator in determining the Medicaid share. CMS also clarifies
that “. . . the EHR incentive payment calculation requires the inclusion of only paid inpatient-bed days.
. . . For purposes of calculating the Medicaid hospital incentive, the Medicaid Share is established in
the base year.” CMS is clarifying that EHR incentive payment are not subject to the same limits as
FY2015: 1 percent payment reduction
FY2016: 2 percent payment reduction
FY2017 and thereafter: 3 percent payment reduction
25
payment for items and services provided to Medicaid beneficiaries and the uninsured including
Medicaid upper payment limits and Disproportionate Share Hospital limit.
Medicaid eligible hospitals are not required to participate on a consecutive annual basis; however, the
last year an eligible hospital may begin receiving payments is 2016, and the last year any eligible
hospital can receive payments is 2021. There are no Medicaid payment penalties for eligible hospitals
that do not meet the meaningful use requirements by a particular date.
Medicaid Incentive Payments for EPs
Federal Register pages 44491 - 44497
An EP that qualifies under both the Medicare and Medicaid EHR incentive programs must notify CMS,
upon registration, whether he/she elects Medicare or Medicaid incentive payments. Qualifying EPs
may switch payment programs only once prior to 2015.
Final Rule: CMS is finalizing its proposed rule with some clarifications. Medicaid incentive
payments to qualifying EPs are to be based on 85 percent of the net average allowable costs of
purchasing, installing, and maintaining certified EHR technology and are to be paid out over a six-year
period. The Secretary has determined the net average allowable cost of EHR to be $54,000 (first year)
and the average maintenance cost at $20,610 (following years) per professional. The HITECH Act
caps the net average allowable costs at $25,000 in the first payment year and $10,000 each payment
year thereafter. Hence, the maximum Medicaid payment for qualifying EPs is $21,250 in the first
payment year and $8,500 in each subsequent year, for up to six payment years. The maximum total
Medicaid incentive payment, over six years, is capped at $63,750 (see chart below). Pediatricians with
high Medicaid patient volumes (between 20 percent and 29 percent of total patient volume) qualify for
additional incentive payments.
A Medicaid EP can receive up to $29,000 in payments from outside sources and still receive 85 percent
of the maximum capped net average allowable cost of $25,000 (which equals $21,250). Payments from
state or local governments are not applied as reductions to the average allowable costs. CMS clarifies
CY 2011 CY 2012 CY 2013 CY 2014 CY 2015 CY 2016
CY 2011 $ 21,250
CY 2012 $ 8,500 $ 21,250
CY 2013 $ 8,500 $ 8,500 $ 21,250
CY 2014 $ 8,500 $ 8,500 $ 8,500 $ 21,250
CY 2015 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $ 21,250
CY 2016 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $ 21,250
CY 2017 $ 8,500 $ 8,500 $ 8,500 $ 8,500 $ 8,500
CY 2018 $ 8,500 $ 8,500 $ 8,500 $ 8,500
CY 2019 $ 8,500 $ 8,500 $ 8,500
CY 2020 $ 8,500 $ 8,500
CY 2021 $ 8,500
Total $ 63,750 $ 63,750 $ 63,750 $ 63,750 $ 63,750 $ 63,750
First Qualifying Year:
26
that any payments that are subtracted from the average allowable cost to determine the net average
allowable cost must be cash payments that are “. . . directly attributed to the professional for the
certified EHR technology.” In the situation where a Medicaid EP is in a contract relationship with an
employer and provided with the certified EHR technology, CMS does not believe that “. . . there could
be any payments directly attributed to the professional for the certified EHR technology; therefore,
there are no payments that must be subtracted. . . . Additionally, States should consider that any in-kind
contributions such as EHR technology or free software provided by vendors are not cash payments and
therefore are also not costs that must be subtracted. Further, in the case of grants like the HRSA
Capital Improvement Program grants that are used to finance many projects within an organization,
for example research projects, infrastructure, construction or repair and renovation of health centers,
health care services, etc., we do not believe these grants are directly attributed as payments for the
certified technology but rather are payments for several projects of the organization. Again, we do not
believe that these costs are directly attributed to payment costs for the certified technology and
therefore must be subtracted.”
Medicaid incentive payments to qualifying EPs may begin as late as 2016 and the qualifying EP can
still receive up to the maximum payment. Qualifying EPs are not required to participate in consecutive
years. There are no payment penalties for EPs that do not become meaningful users by any certain
date.
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