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EHR Frequently Asked Questions

  1. Who is responsible for tracking patient encounters and calculating the EP's patient volume?
  2. Will the patient volume be validated and if so, by whom?
  3. If claims are not used to determine apatient encounters, how should they be identified? Is there a report that can be run by an EHR?
  4. Can Medicaid be the secondary insurer when determining total Medicaid patient encounters?
  5. How will encounters be identified for a Nurse Practitioner that has services billed under one or more physicians in the practice?
  6. If a Nurse Practitioner (NP) works in a pediatrician's office and the pediatrician only meets the 20% Medicaid patient volume, does the requirement for the NP to meet the 30% patient volume still apply?
  7. If a Nurse Practitioner (NP) works in a Family Practice office where the physician patient volume threshold meets 30%, but the NP Medicaid patient volume is only 28% and bills under the physician, does the NP qualify for an incentive even though she does not meet the 30% patient volume?
  8. I know at one point Behavior Health/Psychiatrist were excluded from being eligible physicians for HITECH. Is this still the case or are psychiatrists eligible?

    a)I qualify to apply for an incentive payment; I work for a Behavioral Health Group. How do I apply for an EHR payment?     >


  9. What is the first step in getting started? Is there a number I can call for more information?
  10. I noticed on your website that EPs must verify they have paid at least ($3,750 for year 1 and $1,500 for year 2 through 6). If a Hospital or Home Office paid for the technology, is the EP still eligible for incentive payments for EHR technology?
  11. Is a PA in a FQHC eligible for incentives only if the PA is the patient's primary provider or does the PA have to be the primary provider of the FQHC?
  12. If a patient's primary provider is a physician but the patient is occasionally seen by a PA, would the PA qualify for incentives?
  13. Are PAs in physician offices, other than a FQHC qualified for incentives?
  14. Is there any issue with EPs applying for Medicaid incentives and being associated with the same TIN as the hospital that will also be applying for MU incentives?
  15. We know that the billing provider NPI # is used to verify patient volume for EPs that choose to use group encounters to meet eligibility requirements.

    a) Does this mean the TIN has no bearing on eligibility requirements?

    b) Will EPs use the billing provider NPI # for their main satellite office if they want to apply using group encounters or will they use the billing provider NPI#s of all 4 locations together?

    c) Several physicians practice at multiple locations. Will they use the billing provider NPI # of all locations where they work to calculate group patient volume?


  16. Are there any ramifications to EPs meeting the 30% Medicaid threshold knowing that the majority of EPs under the same TIN # will not be applying for incentives because they have not yet implemented an EHR?
  17. As the non-EHR professionals adopt EHR technology (sharing the same TIN # as the EHR early adopters), will their Medicaid patient volume percentages affect the group practice volume percentages if the group practice qualifies as a group meeting the 30% Medicaid threshold?
  18. One physician sees patients in a traveling van and all of his patients are considered charity care. Will he be eligible for Medicaid incentives based on the .needy individuals. definition -patients furnished uncompensated care by the provider or services at no cost?
  19. For the first participation year, an EP only has to Adopt, Implement, or Upgrade an EHR to receive incentives. For the following years, the EP must meet certain objectives and measures during a specified reporting period. For year 2 and later, if a physician practices at several locations, will all locations be taken into consideration to meet the objectives or will only the primary practice location be utilized?
  20. For a FQHC, do free care encounters, charity care encounters, and sliding scale encounters count toward meeting the 30% eligibility requirement?
  21. How is an encounter defined for purposes of determining patient volume?
  22. What is the time period for attesting to meaningful use?
  23. Are EPs and EHs eligible to attest to meaningful use in the first payment year instead of attesting to adoption, implementation, and upgrade?
  24. Where can Meaningful Use standards be found?
  25. What are the requirements for Stage 1 of Meaningful Use (2011 and 2012)?
  1. Who is responsible for tracking patient encounters and calculating the EP's patient volume?

    Providers are responsible for tracking patient encounters. Calculation of the patient volume for program eligibility will be determined by the Division of Medicaid and Medical Assistance (DMMA) based on the encounter information entered by a provider through the DMAP incentive program web portal (MAPIR). Patient volume must be broken out for each Medicaid managed care company and for fee for service Medicaid claims. Providers that are working for more than one group and are claiming individual encounter volumes must list encounters from all groups. The portal will be established in mid 2011.
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  2. Will the patient volume be validated and if so, by whom?

    The Division of Medicaid and Medical Assistance (DMMA) anticipates validation of Medicaid encounters (numerator) through claim data or panel volume for the reporting period. If the Medicaid encounters related to an EP are submitted by an MCO, and the EP’s NPI is not on the encounter, the PIP team will request validation of the encounters from the MCO claims system. Providers will need to maintain adequate records that can validate the total patient encounters (denominator) reported from all sources. DMMA will audit individual providers to ensure program integrity. Additional information will be requested from providers to support the patient volume provided for program eligibility. Incentive payments are paid with Federal Funds. Falsification or concealment of a material fact may be prosecuted under Federal and State laws.
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  3. If claims are not used to determine patient encounters, how should they be identified? Is there a report that can be run by an EHR?

    DMMA expects providers will use claim data, panel volume, or some type of reporting from an EHR or Practice Management System to determine patient encounters. Total provider patient encounters could require data from several different sources.
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  4. Can Medicaid be the secondary insurer when determining total Medicaid patient encounters?

    When calculating eligible professional or eligible hospital Medicaid patient encounter, Medicaid must pay for all or part of the service or pay for all or part of the individual's premiums and co-payments. If Medicaid pays nothing toward the service then the encounter cannot be counted in the Medicaid numerator.

    When calculating eligible professional patient volume at a FQHC/RHC location, Medicaid or CHIP must pay for all or part of the service or pay for all or part of the individual's premiums and co-payments, unless the service is offered to an underserved individual at no cost or at a reduced cost.
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  5. How will encounters be identified for a Nurse Practitioner that has services billed under one or more physicians in the practice?

    The performing provider NPI will be used to verify patient volume for professionals that choose to report their individual encounters to meet eligibility requirements of the incentive program. The billing provider NPI will be used to verify patient volume for professionals that choose to use the group encounters to meet eligibility requirements of the incentive program and that bill under the group NPI. Regardless of performing provider NPI, the billing NPI will represent all encounters for the group practice.
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  6. If a Nurse Practitioner (NP) works in a pediatrician's office and the pediatrician only meets the 20% Medicaid patient volume, does the requirement for the NP to meet the 30% patient volume still apply?

    Yes, the NP must meet the 30% patient volume. Medicaid patient volume required for program eligibility must be consistent with the type of professional applying. In this scenario, the NP needs to have a 30% Medicaid patient volume and the Pediatrician must have a 20% patient volume, even if the professionals are using the group encounter volume to meet program eligibility. The NP qualifies for the full incentive and the Pediatrician qualifies for 2/3 of the incentive.
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  7. If a Nurse Practitioner (NP) works in a Family Practice office where the physician patient volume threshold meets 30%, but the NP Medicaid patient volume is only 28% and bills under the physician, does the NP qualify for an incentive even though she does not meet the 30% patient volume?

    No, a NP must meet 30% Medicaid patient volume to be eligible for the incentive program. (see 495.304 (c) (1) at 75 FR 44578). Billing provider information is only used when an Individual uses the group patient volume to meet eligibility. This is not based on a group scenario as the two individuals have different patient volumes.
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  8. I know at one point Behavior Health/Psychiatrist were excluded from being eligible physicians for HITECH. Is this still the case or are psychiatrists eligible?

    Only physicians that are defined in the DMAP Enrollment Application are able to apply for incentives. Here is a link to the DMAP Provider Enrollment Application. Please also see the DMMA website that refers to Eligible Professionals (EP).

    a) I qualify to apply for an incentive payment; I work for a Behavioral Health Group. How do I apply for an EHR payment?
    Eligible EP’s attached to Behavioral Health Group must use Individual volumes. An EP cannot list a Behavioral Health Group as a payee since Behavioral Health is excluded from being eligible at this time.
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  9. What is the first step in getting started? Is there a number I can call for more information?

    Anyone interested in applying for the incentive program will first need to register with the at Center for Medicare and Medicaid Services (CMS). Once the DMAP Program is established, registration will be forwarded from CMS to DMMA, and Providers can then enter additional information through an online application process. We expect to accept additional application information by June of 2011.
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  10. I noticed on your website that EPs must verify they have paid at least ($3,750 for year 1 and $1,500 for year 2 through 6). If a Hospital or Home Office paid for the technology, is the EP still eligible for incentive payments for EHR technology?

    This no longer requires verification. CMS has assumed an average allowable cost for providers that satisfy this requirement.
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  11. Is a PA in a FQHC eligible for incentives only if the PA is the patient's primary provider or does the PA have to be the primary provider of the FQHC?

    PAs are not eligible for incentives. The Final rule says that a PA is eligible only when practicing at a Federally Qualified Health Center (FQHC) that is .led by a PA. and if the individual provider is within the scope of practice defined under state law. Currently, there are no FQHC.s in Delaware that are .led by a PA. as defined in the CMS Final Rule. Additionally, PAs are not within the scope of practice defined under Delaware Medicaid Regulations. DMAP enrolls PAs for Medicare Crossover only services to allow payments for the clients co-insurance &/or deductible.
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  12. If a patient's primary provider is a physician but the patient is occasionally seen by a PA, would the PA qualify for incentives?

    No, see answer to FAQ #11.
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  13. Are PAs in physician offices, other than a FQHC qualified for incentives?

    No, see answer to FAQ #11.
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  14. Is there any issue with EPs applying for Medicaid incentives and being associated with the same TIN as the hospital that will also be applying for MU incentives?

    No, the TIN is only used for payment of incentives. The hospital can receive incentive payments under this TIN and Eligible professionals can assign payments to this TIN if they choose.
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  15. We know that the billing provider NPI # is used to verify patient volume for EPs that choose to use group encounters to meet eligibility requirements.

    a) Does this mean the TIN has no bearing on eligibility requirements?
    Correct.

    b) Will EPs use the billing provider NPI # for their main satellite office if they want to apply using group encounters or will they use the billing provider NPI#s of all 4 locations together?
    Group practice may determine the volume of Medicaid and total encounters for the group and allow their providers to use this volume. This is not dependent on the service locations as there could be one or many locations for the group. Medicaid expects groups to be enrolled with the NPI that represents the group and is used for billing for the individual provider.s services in that group. If a provider is a member of multiple groups that are allowing the group volume to be used for this program, the EP should select only one group volume to report. This is sufficient to make them eligible to participate in the program. Meaningful use must be met at the individual level to receive an incentive. See the CMS Frequently Asked Questions.

    c) Several physicians practice at multiple locations. Will they use the billing provider NPI # of all locations where they work to calculate group patient volume?
    Group practice may determine the volume of Medicaid and total encounters for the group and allow their providers to use this volume. This is not dependent on the service locations as there could be one or many locations for the group. Medicaid expects groups to be enrolled with the NPI that represents the group and is used for billing for the individual provider.s services in that group. If a provider is a member of multiple groups that are allowing the group volume to be used for this program, the EP should select only one group volume to report. This is sufficient to make them eligible to participate in the program. Meaningful use must be met at the individual level to receive an incentive. See the CMS Frequently Asked Questions.
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  16. Are there any ramifications to EPs meeting the 30% Medicaid threshold knowing that the majority of EPs under the same TIN # will not be applying for incentives because they have not yet implemented an EHR?

    There are no ramifications. Medicaid realizes that individuals, groups, and hospitals will often be on different schedules for implementation of Certified EHR systems, regardless of the TIN.
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  17. As the non-EHR professionals adopt EHR technology (sharing the same TIN # as the EHR early adopters), will their Medicaid patient volume percentages affect the group practice volume percentages if the group practice qualifies as a group meeting the 30% Medicaid threshold?

    The encounter volume is for all individuals within the practice and is not based on the quantity of the individuals that seek the incentive payment.
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  18. One physician sees patients in a traveling van and all of his patients are considered charity care. Will he be eligible for Medicaid incentives based on the .needy individuals. definition -patients furnished uncompensated care by the provider or services at no cost?

    No, the .needy individuals. definition applies to FQHC volume only.
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  19. For the first participation year, an EP only has to Adopt, Implement, or Upgrade an EHR to receive incentives. For the following years, the EP must meet certain objectives and measures during a specified reporting period. For year 2 and later, if a physician practices at several locations, will all locations be taken into consideration to meet the objectives or will only the primary practice location be utilized?

    Providers who practice at multiple locations must have 50 percent of their total patient encounters at locations where certified EHR technology is utilized to meet meaningful use requirement.
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  20. For a FQHC, do free care encounters, charity care encounters, and sliding scale encounters count toward meeting the 30% eligibility requirement?

    Yes, this meets the CMS definition of "needy individual".
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  21. How is an encounter defined for purposes of determining patient volume?

    Federal rules allow the services below to be considered Medical Assistance encounters for calculating patient volume. For Eligible Professionals: Services rendered on any one day to an individual where Medical Assistance paid for part or all of the service or their premiums, co-payments and/or cost-sharing. For Hospitals: Services rendered to an individual per inpatient discharges where Medical Assistance paid for part or all of the service or their premiums, co-payments and/or cost-sharing. Services rendered to an individual in an emergency department on any one day where Medical Assistance paid for part or all of the service; or their premiums, co-payments and/or cost-sharing.
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  22. What is the time period for attesting to meaningful use?

    Eligible Professionals (EPs) will have the option to attest to adopting, implementing or upgrading in their first participation year. In the second participation year, EPs must attest to the meaningful use criteria for any continuous 90 day period within the same payment year (calendar year). In subsequent payment years (calendar years), EPs will need to attest to MU requirements for 365 days.

    Eligible Hospitals (EHs) will have the option to attest to adopting, implementing or upgrading in their first participation year. In the first participation year, Eligible Hospitals must attest to the MU requirements for 90 days within their payment year (Federal Fiscal Year). In subsequent payment years, Eligible Hospitals must meet the MU requirements for 365 days within their payment years (Federal Fiscal Years).
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  23. Are EPs and EHs eligible to attest to meaningful use in the first payment year instead of attesting to adoption, implementation, and upgrade?

    Eligible Professionals must attest to Adopting, Implementing or Upgrading (AIU) to a certified EHR System in the first participation year. In subsequent participation years, Eligible Professionals and EHs must attest to meeting the meaningful use criteria. Only hospitals that are 1) dually eligible for both the Medicare and Medical Assistance EHR incentive programs and 2) attesting to meaningful use under Medicare in 2011 should attest to meaningful use in MAPIR.
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  24. Where can Meaningful Use standards be found?

    Medical Assistance Meaningful Use requirements are posted on the CMS website:

    Eligible Professionals Link

    Eligible Hospitals Link

    Guide to CQM's
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  25. What are the requirements for Stage 1 of Meaningful Use (2011 and 2012)?

    In Calendar Year 2011 Delaware asked EPs to attest to A/I/U of EHR.
    EHs may attest to Stage 1 of MU in April 2012. EPs are projected to be able to attest to MU in Summer 2012.
    Meaningful use includes both a core set and a menu set of objectives that are specific to Eligible Professionals or Eligible Hospitals and Critical Access Hospitals (CAHs).

    For EPs, there are a total of 25 meaningful use objectives. To qualify for an incentive payment, 20 of these 25 objectives must be met.

    a) There are 15 required core objectives.
    b) The remaining 5 objectives may be chosen from the list of 10 menu set objectives.

    For eligible hospitals and CAHs, there are a total of 24 meaningful use objectives. To qualify for an incentive payment, 19 of these 24 objectives must be met.

    a) There are 14 required core objectives.
    b) The remaining 5 objectives may be chosen from the list of 10 menu set objectives.

    CMS EHR Meaningful Use Criteria Summary

    The criteria for meaningful use will be staged in three steps over the course of the next five years.

    • Stage 1 (2011 and 2012) sets the baseline for electronic data capture and information sharing.
    • Stage 2 (expected to be implemented in 2014) and Stage 3 (expected to be implemented in 2015) will continue to expand on this baseline and be developed through future rule making.
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If you need assistance selecting and using an EHR system, contact the Delaware Regional Extension Center

If you would like more information on the DMAP Provider Incentive Program for Electronic Health Records please direct your inquiries to Delaware Provider Incentive Payment Team