Eligibility to Participate in the Michigan Medicaid EHR Incentive Program
Participation in the Michigan Medicaid EHR Incentive Program will require an eligible professional (EP) to meet numerous program requirements. A provider is not an “EP” unless all of these requirements are met.
It is also important to note that this program is for the individual EP. The individual EP must meet eligibility and meaningful use requirements, attest and receive payment. The individual EP may also be audited, so EPs should be active in the program process and provide accurate information to avoid recoupment of incentive dollars by the state of Michigan.
Note: Beginning in 2015, Providers who do not meet the minimum Medicaid threshold to participate in the EHR Incentive program can submit an “alternate attestation” through the CMS site to avoid the Medicare Payment adjustments https://ehrincentives.cms.gov/hitech/login.action. Please refer to the “Alternate Medicare Attestation Guide” for further information.
Eligible Professional Types
EPs must be Michigan Medicaid providers who physically practice in the state and belong to one of the following professional types:
- Physicians (M.D. or D.O.)
- Dentists (D.D.S. or D.M.D.)
- Optometrists (O.D.)
- Nurse Practitioners (NP)
- Certified Nurse-Midwives (CNM)
- Physician Assistants (PA) practicing in a PA-led Federally Qualified Health Center (FQHC) or a PA-led Rural Health Clinic (RHC)
Eligibility and “Encounters”
Eligibility for Medicaid EHR incentives is largely determined by several “encounter” calculations. To do these calculations, we must first define terms:
- Eligibility reporting period:
- A continuous representative 90-day period during which the EP demonstrates that he or she has maintained adequate Medicaid-eligible patient volume. Encounters used for calculating eligibility must fall within this 90-day period. This 90-day period must be (a) within the 12 months preceding the date of EP registration/attestation or (b) within the previous calendar year (January 1st through December 31st).
- Total encounters:
- An encounter occurs when a medical service is rendered to an individual on a date falling within the 90-day eligibility reporting period. Multiple claims for the same patient, on the same day, count as only one encounter.
- Medicaid encounter:
- A Medicaid encounter occurs when an EP provides a medical service to a Medicaid-enrolled patient on a date falling within the 90-day eligibility reporting period. A “zero-pay” claim is counted as a Medicaid encounter. Multiple claims for the same patient, on the same day, count as only one encounter.
- Beginning January 1, 2016 all providers can include MiChild encounters in their Medicaid Encounter Totals. EPs practicing at an FQHC or RHC and using Needy Individual encounters should now include MiChild encounters in their Medicaid Encounter Totals and not in their Needy Individual Encounters.
- Hospital encounter:
- A hospital encounter occurs when a medical service is rendered to an individual on a date falling within the 90-day eligibility reporting period using Place of Service (POS) codes 21 (inpatient) and/or 23 (emergency department). Multiple claims for the same patient, on the same day, count as only one encounter.
Calculation to Determine If an EP is Non-Hospital Based
EPs must be non-hospital based to participate. Non-hospital based is currently defined as a medical professional who provides less than 90% of their total encounters in a hospital setting during the eligibility reporting period. Non-hospital based is calculated by dividing an EP’s total hospital encounters by their total encounters.
Calculation of Medicaid Patient Volume
EPs must meet a minimum Medicaid patient volume threshold. Medicaid patient volume is calculated by dividing total Medicaid encounters by total encounters.
To participate in the Incentive Program, an EP’s Medicaid patient volume must meet or exceed a threshold:
- Most EPs must have a minimum 30% patient volume attributable to encounters with Michigan Medicaid-enrolled patients.
- Pediatricians only need a minimum 20% patient volume attributable to encounters with Michigan Medicaid-enrolled patients.
- For those who practice predominantly in an FQHC or RHC, a minimum 30% needy individual patient volume is required. Needy individuals include Medicaid encounters, charity care and sliding-fee encounters.
Additional Details and Options for Calculating Medicaid Patient Volume Thresholds
- Out of State Medicaid encounters may be included in the calculations.
- Individual EPs may include managed care organization (MCO) panel-assigned patients.
- Instead of using individual encounter data, the EP may use group encounter data (group-proxy option).
- EPs working predominantly in a FQHC or RHC may include needy individual encounters.
Certified EHR Technology (CEHRT)
Before EPs can meet MU requirements, they must acquire or have access to a CEHRT. EHR certification is conducted by an Office of the National Coordinator for Health Information Technology (ONC) Authorized Testing and Certification Body.
All certified EHR products appear on the Certified Health IT Products List (CHPL). Products can be certified as stand-alone EHRs, capable of meeting MU on their own, or as separate modules pieced together to achieve MU functionality. The CHPL will assign each EHR, or group of modules, a CMS EHR Certification ID. This ID is required for registration.
Find your Certified EHR product below:
ONC-Certified Health IT Product List
For Further Assistance
Please click on the Contact button – at the top of every page – for further support on the Michigan Medicaid EHR Incentive Program. Or check out the “EP Guide to Medicaid EHR Incentive Program” for more complete information.