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Information for Providers

Should Providers Apply?

Providers need to ask themselves a series of questions to determine if they should apply for EHR incentives either through the Medicare or Medicaid programs.

Is the provider an eligible professional or hospital? There is significant “eligibility” differences between Medicare vs. Medicaid, providers need to look at the eligibility criteria and take that into consideration when deciding whether or not to apply.  Providers who furnish substantially all their services in a hospital setting are not eligible for the EHR incentive programs and for hospitals, the Medicare eligibility rules are generally more inclusive. It is possible for a provider to be an eligible professional under Medicare, Medicaid, both or neither; however, providers can only participate in one program. Hospitals may qualify to participate in both the Medicare and Medicaid programs.

What are the financial implications of applying? The provider needs to consider the costs of complying vs. the incentives and possible penalties. Incentive funds only cover about 85% of the expected implementation costs. Incentive payment calculations under Medicare and Medicaid are different so providers will need to determine their payments under both to help determine which program to apply to. Providers need to determine if they will be ready to demonstrate meaningful use. Providers can demonstrate Stage 1 compliance as late as 2014 and still receive incentive funds.  The EHR Incentive Program provides funds for “efforts to adopt, implement or upgrade certified EHR technology”. The rules of the program do not prohibit: shared solutions, using a third party service provider, partnering with others, or other creative means for implementing EHR capabilities.

What measures is the provider currently reporting? Providers should not assume the final measures will exactly match existing program measures. Even if a provider already captures and reports a specific measure, additional work may be needed to achieve meaningful use.

Providers will need to assess their data process and workflow, including office layout and placement of computer terminals. The “where” and “When” in the day-to-day operations will the information be electronically captured?  In “what” system(s) will the electronic capture of information occur?

Providers will need to determine their individual paths to certify their EHR. The provider will need to consider: whether or not they will use a vendor, will they pursue internal system certification, will they use a service partner, will they partner with other providers or will they explore other options. Providers will also need to consider expanding existing quality reporting tools vs. implementing new tools.  The federal goal is to harmonize these measures over time since many overlap with measures required y other programs.