Medicare and Medicaid EHR Incentive Programs:
What Do They Mean to You?
In July of 2010, the Centers for Medicare and Medicaid Services (CMS) enacted the Medicare and Medicaid Electronic Health Record Incentive Programs, which were authorized as part of the Health Information Technology for Economic and Clinical Health (HITECH) Act of 2009.
This initiative provides financial incentives to eligible hospitals and clinicians (including dental practices) that use electronic health records (EHRs). Dentists are eligible for the Medicaid EHR Incentive Program, while only oral surgeons are eligible for the Medicare EHR Incentive Program.
Determining Your Eligibility
What percentage of your patient volume is covered by Medicaid?
To qualify for a Medicaid EHR incentive payment, 30% of your patient encounters in any continuous 90-day period from the prior calendar year must have been covered by Medicaid.
Exception
If more than half of your encounters during six months of the prior calendar year took place at a federally qualified health center or rural health center, you can include other "needy individuals"—even if they don’t have Medicaid—in your calculations. Needy individuals are defined as those who receive:
- Medical assistance from Medicaid
- Medical assistance from the Children's Health Insurance Program
- Uncompensated care by the healthcare provider
- Services at either no cost or reduced cost based on a slilding scale determined by the individual's ability to pay
Group practices
If you work in a group practice, you can use the practice’s total patient volume to make your calculations. In other words, if the total practice across all staff has a patient volume of at least 30%, then each individual dentist can qualify as having 30% for purposes of the Medicaid EHR Incentive Program.
Do you use certified EHR technology?
To qualify for the program, you must own or have access to certified EHR technology that has been certified by the Office of the National Coordinator for Health Information Technology (ONC). You must also be able to demonstrate "meaningful use" of that technology (see below for more information). Reporting requirements vary, depending on how many years you’ve participated in the program:
First year. In your first year of the Medicaid EHR Incentive Program, simply having adopted or upgraded to certified EHR technology will suffice for you to receive an incentive payment. No additional reporting is necessary.
Second year. You must demonstrate meaningful use of your certified EHR technology for a period of 90 days.
Third and subsequent years. You must demonstrate meaningful use of your certified EHR technology for the entire 12 months.
For example, if you register for the program any time in 2011, you would use the following reporting schedule:
- 2011 - Show proof of having adopted or upgraded to certified EHR technology
- 2012 - Demonstrate meaningful use of the technology for a period of 90 days
- 2013 and beyond - Demonstrate meaningful use of the technology for 12 months
Meaningful use criteria
"Meaningful use" simply means that you must prove that your EHR technology is being used in measurable ways. The CMS website calls out three main components:
- The use of a certified EHR technology in a meaningful manner, such as e-prescribing
- The use of certified EHR technology for electronic exchange of health information to improve quality of healthcare
- The use of certified EHR technology to submit clinical quality and other measures
There are 25 defined meaningful use objectives. If you are eligible for the program, you’ll be required to meet 15 core objectives and at least five other measures from a list of 10. You can find the complete list and explanations on the CMS website.
Henry Schein is Working to Make the Program Fit Your Needs
Right now, many of the core meaningful use objectives don’t apply to oral healthcare providers and this makes it very difficult for the average dentist to participate in the program.
For instance, if you have a patient with diabetes, the program requires you to be able to electronically track this condition as well as the patient’s diabetes medications. You could state “unknown” in fields related to such medical conditions and probably still meet the meaningful use criteria—but your dental practice management system will still have to be able to record a patient’s full medical history (not just oral health history) in order to be certified.
Dentrix dental practice management software can receive modular certification. This, however, does not fully solve the problem and you may have to invest in other systems that together meet all 15 core objectives and measures.
Henry Schein Practice Solutions is working with several groups, including the ADA, CMS, Health Resources and Services Administration (HRSA), National Network for Oral Health Access (NNOHA) and the American Association of Oral and Maxillofacial Surgeons (AAOMS), to highlight the need for a certification standard specifically for electronic dental records (EDRs) that will make the program more accessible to oral health professionals. We are developing a list of oral health measures to submit to CMS and requesting they be included in the definitions of meaningful use.
We are also participating in the ADA workgroup for EDR standards with the goal of creating a certification for EDRs that can apply more easily to the CMS meaningful use criteria.
For more information about eligibility requirements, the program timeline and how to register, please visit the
CMS website.