Eligible Professional (EP) FAQs

What types of Health Care Professionals qualify as an Eligible Professional?

  • Provider Type: Eligible Professional
  • Category: Eligibility

The following types of Health Care Professionals are eligible to apply for the Medicaid EHR Incentive Program as long as they meet Medicaid patient volume requirements.

  • Eligible Professional Types
    • Physicians (M.D. and D.O.)
    • Nurse practitioners
    • Certified nurse-midwives
    • Dentists
    • Physician assistants who practice in a Federally Qualified Health Center or Rural Health Clinic that is led by a physician assistant

What physician specialties can qualify as an Eligible Professionals?

  • Provider Type: Eligible Professional
  • Category: Eligibility

Physicians (M.O. and D.O.) fall under the provider types that are eligible to apply for the Medicaid EHR Incentive Program as long as they meet Medicaid patient volume requirements. There is no restriction on specialty or location of clinical practice. The one exception that does exclude a physician from being eligible is that the physician cannot be "hospital-based". The term hospital-based can be defined as rendering more than 90% of covered professional services in the inpatient acute care or emergency department settings.

Eligible Provider Types

  • Physicians (M.D. and D.O.)
  • Nurse practitioners
  • Certified nurse-midwives
  • Dentists
  • Physician assistants who practice in a Federally Qualified Health Center or Rural Health Clinic that is led by a physician assistant

Most of the professionals that work for us do so as subcontractors and they do similar work for other employers/entities as subcontractors. In such a situation, where subcontractors are associated with more than one entity, can the incentive be assigned and shared by the entities or would it be on a first come basis?

  • Provider Type: Eligible Professional
  • Category: Incentive Payment

Eligible Professionals (EPs) are permitted to reassign their incentive payments to their employer or to an entity with which they have a contractual arrangement allowing the employer or entity to bill and receive payment for the EP's covered professional services.

Payments will be issued directly to the individual provider, unless the provider voluntarily chooses to reassign the payment to his or her employer during the process of registering in the incentive program.

Reassignment of the incentive payment is limited to totally assigning the payment to a single entity - it will not be possible to reassign only part of the incentive payment or to split the reassignment among multiple entities.

Can Eligible Professionals in a group practice use a common Medicaid Patient Volume?

  • Provider Type: Eligible Professional
  • Category: Medicaid Patient Volumne

Providers in a group practice may use the group practice patient volume as a proxy for individual Medicaid Patient Volume. Group practices may choose to use the overall practice's aggregate patient volume numbers as a proxy for the individual EPs within the practice, but to take advantage of this option all the EPs in the practice must use the group numbers (i.e., if one EP uses the group's aggregate numbers, another EP in the practice may not use his/her individual values, and vice-versa). A group opting to use the aggregate patient volume may use either the standard or managed care methods (as described above) for calculating patient volume.

Would you please explain the Medicaid Patient Volume calculation?

  • Provider Type: Eligible Professional
  • Category: Medicaid Patient Volumne

EPs who wish to enroll in the Medicaid EHR Incentive Program must demonstrate that at least 30% of their patient volume is attributed to Medicaid, over a 90-day reporting period. This period must be entirely within the calendar year prior to the payment year (so, if you register in 2011, the period must be entirely in CY 2010), and it must be "representative" of the provider's overall practice, but otherwise each EP is free to select any 90 consecutive days as the patient volume reporting period.

  • In the simplest calculation method, an EP counts the number of patient encounters during the 90-day reporting period that were paid all or in part by Medicaid, and divides that number by the total number of patient encounters over the same period.
  • EPs who have significant managed care populations might use a more complex calculation that takes into account the number of managed care patients on their patient panel during the 90-day reporting period, whether or not the EP actually had an encounter with those patients during the period. For more information on this method go to http://nyhealth.gov/regulations/arra/docs/medicaid_health_information_technology_plan.pdf (PDF, 11.7MB, 410pg.)

Group practices may choose to use the overall practice's aggregate patient volume numbers as a proxy for the individual EPs within the practice, but to take advantage of this option all the EPs in the practice must use the group numbers (i.e., if one EP uses the group's aggregate numbers, another EP in the practice may not use his or her individual values, and vice-versa). A group opting to use the aggregate patient volume may use either the standard or managed care methods (as described above) for calculating patient volume.

What are the sign up steps Eligible Professionals (EPs) need to take to participate in the Medicaid EHR Incentive Program?

  • Provider Type: Eligible Professional
  • Category: General Program Information

Eligible professionals who wish to participate in either the Medicare or Medicaid EHR Incentive Program must first register with CMS using the "Medicare & Medicaid EHR Incentive Program Registration and Attestation System". This is the primary control that ensures that providers can't participate in both programs. To log in to that system, EPs need to have an National Provider Identifier and a National Plan and Provider Enumeration System (NPPES) web user account. If an EP does not have an NPI, or has an NPI but does not have an NPPES web user account, he or she must visit the NPI portion of NPPES to apply for an NPI or create a login for the existing NPI.

For additional resources check the CMS website page "What can you do now for the Medicare and Medicaid EHR Incentive Programs?"

You can also review the CMS Registration User Guide for Eligible Professionals for the Medicaid program which shows the whole registration process step-by-step.

For more specific answers on how to get access to the incentive program registration at the federal level, there is an Electronic Health Records (EHR) FAQ on CMS External User Services.

In addition to other eligibility requirements, Eligible Professionals must have greater than 50% of their encounters in a location or locations with certified EHR technology available at the start of the reporting period. How do EP's who are working in multiple locations with ONC Certified EHR Technologies attest to meaningful use measures?

  • Provider Type: Eligible Professional
  • Category: Eligiblity, Attestation

It is important to note that the Medicaid EHR Incentive Program does not require that participants achieve meaningful use of EHR technology in their first year of participation. While the requirement that EPs provide at least 50% of their services in a location equipped with EHR technology applies in the first year, there is no requirement to gather meaningful use measures until the second participation year. Presumably, by that time the EHR technology will be well-established and it will be less of a burden to gather the meaningful use measures since it is expected that the EHR will have the capability to generate meaningful use reports.

That said, the discussion of "EPs Practicing in Multiple Practices" on page 44329 of the Final Rule for the Medicare and Medicaid EHR Incentive Programs 1 makes it clear that in the calculation of meaningful use measures, each EP must include encounters that occur in any practice location equipped with certified EHR technology at the start of the EHR reporting period. Although we understand the desire on the part of health care facilities to leverage efficiencies of scale in calculating eligibility and meaningful use measures on behalf of their practitioners, the intent of the legislation enabling the incentive program was clear in that the determination of meaningful use is specific to each practitioner based on his or her own clinical practice. CMS has chosen to allow certain administrative simplifications (such as the use of group practice patient volume as a proxy for individual volume) - especially for criteria that must be satisfied before the EHR may be fully operational and able to provide system-generated reports - but meaningful use remains an individual determination.

To be eligible for the EHR incentive program, how does an Eligible Professional become enrolled in NY Medicaid?

  • Provider Type: Eligible Professional
  • Category: General Program Information

Each practitioner will need to take certain steps in order to apply for the incentive. Some of these steps will involve accessing registration and attestation system called the NY Medicaid EHR Incentive Program Application Support Service (MEIPASS). In order to access this system, the practitioner will need to have an account in the ePACES system, which requires that the practitioner is an active enrolled Medicaid fee-for-service provider. Additionally, the incentive payments will be disbursed as a lump sum payment through the existing channels for paying Medicaid fee-for-service providers, so even practitioners who do not directly bill Medicaid on a fee-for-service basis will need to enroll in order to receive the incentive payment.

All of our practitioners are billed as institutional services, how do we determine a given practitioner's Medicaid patient volume to become eligible for the Medicaid EHR Incentive Program?

  • Provider Type: Eligible Professional
  • Category: Medicaid Patient Volumne

It doesn't matter how Medicaid is billed for the services a practitioner renders to Medicaid beneficiaries. As long as the service is paid all or in part by Medicaid (which includes scenarios where Medicaid pays a premium or co-pay), the service counts as a Medicaid encounter towards the practitioner's minimum Medicaid patient volume. A provider can reach the 30% minimum Medicaid patient volume without ever billing Medicaid directly or even being an enrolled provider.

Footnotes