Congress has appropriated approximately $27 billion as part of the American Recovery and Reinvestment Act to fund incentive payments to both eligible hospitals (EH) and eligible professionals (EP) to acquire, implement, upgrade and use electronic health record (EHR) technology to improve the quality of patient care.  The federal EHR incentives are paid to EHs and EPs for the investment in a federally certified EHR system and demonstrated utilization of EHRs, commonly referred to as “Meaningful Use” or MU.

Both Medicare and Medicaid play key roles in administering these EHR incentives.  The development and implementation of a state Medicaid incentive program is delegated to the State Medicaid Agency, and participation by a State Medicaid Agency is voluntary.

The Department of Public Health and Human Services (Medicaid State Agency) has chosen to participate by developing and implementing the Montana Medicaid Provider Incentive Program (MPIP). The Department is in the initial stages of development.

• Official Website for the Medicare and Medicaid Electronic Health Records (EHR) Incentive Programs
• CMS FAQs
• Mountain-Pacific Quality Health – Health Technology Services Regional Extension Center

How much incentive funding is available?

Doctors and other Eligible Professionals can qualify for incentive payments totaling as much as $63,750 through Medicaid.  Hospitals can qualify for incentive payments potentially totaling $2 million or more.

Who is eligible?

Providers and hospitals meeting specific eligibility and MU criteria are eligible to participate. 

Eligible professionals include: 

• Physicians
• Medical Doctor (MD)
• Doctor of Osteopathy (DO)
• Doctor of Dental Surgery (DDS)
• Doctor of Dental Medicine (DDM)
• Nurse practitioner
• Certified nurse-midwife
• Physician assistant who furnishes services in a federally qualified health center (FQHC) or rural health clinic (RHC) that is led by a physician assistant.

Chiropractors, podiatrists and certain other provider types are not eligible to participate in the Montana MPIP, but may qualify for the Medicare Provider Incentive Program.

Acute care and critical access hospitals (CAHs) may qualify for both Medicaid and Medicare Incentives.

What must a participant do to qualify for an incentive payment?

In order to qualify, providers must first meet Medicaid patient volume thresholds.  Then, qualifying providers must also adopt, implement, upgrade, or demonstrate MU of a certified EHR system in the first year of participation.  MU requires that participants demonstrate use of certified EHR technology in ways that can be measured significantly in quality and in quantity.

During the first incentive payment year, the EP is not required to demonstrate MU to receive payment. During the second payment year the EP would demonstrate MU for a 90-day period only. For payment years three and up, providers must demonstrate MU over a continuous 12-month period.

What are the Medicaid patient volume thresholds?

Acute care hospitals and critical access hospitals (CAHs) must meet an annual minimum Medicaid patient volume threshold of 10% in order to be eligible.

EPs must annually meet the following minimum patient volume threshold for a minimum continuous 90-day period in the preceding calendar year.

Entity	Minimum 90-day Medicaid Patient Volume Threshold	Or the Medicaid EP practices predominately in an FQHC or RHC - 30% “needy individual” patient volume threshold.
Physicians	30%
Pediatricians	20%
Dentists	30%
Certified nurse midwives	30%
Physician assistants when practicing at an FQHC/RCH led by a physician assistant	30%
Nurse practitioner	30%

Hospital-based EPs providing more than 90% of services in an in-patient hospital or emergency room setting are ineligible for EHR incentive programs.

Can a participant count all State of Montana health care program patients?

• EPs cannot count their Healthy Montana Kids (HMK) encounters.
• EPs cannot count their Primary Care Case Management (Passport) fees as encounters.
• EPs can count their Medicare/Medicaid dual eligible encounters.
• EPs practicing predominantly in an FQHC or RHC may count as “needy individuals” those patients meeting any of the following three criteria: (1) They are receiving medical assistance from Medicaid or HMK.
  (2) They are furnished uncompensated care by the provider; or
  (3) They are furnished services at either no cost or reduced charge based on a sliding scale determined by the individual’s ability to pay.