When practices go through the expense of installing an EHR system, and making sure that it fits the bill for “meaningful use”, most expect that their state Medicade agency will follow-up throughly to make sure they’ve fulfilled all the eligibility requirements so they can legally get reimbursed for incentives.
However, a new report put out by the Department of Health and Human Services finds this isn’t always the case.
The report, released on July 15, examined 13 states who had approved plans for the EHR incentive program. What did they find?
They found that all 13 states in the study reported that they planned to verify at least half of the eligibility requirements prior to making EHR incentive payments.
However, they discovered that 12 of the 13 states were not planning on verifying all the eligibility criteria required to qualify for incentive payments. Only the state of Kentucky said they would be checking all criteria before making payments.
Here’s the list of the 13 states studied, as well as the number of eligibility requirements they’ll be checking for before reimbursing clinics.
- Kentucky: 11
- Alaska: 10
- Alabama: 10
- Mississippi: 9
- Tennessee: 9
- North Carolina: 8
- Michigan: 8
- Texas: 7
- Oklahoma: 7
- South Carolina: 7
- Iowa: 7
- Pennsylvania: 7
- Wisconsin: 6
And here’s something more: all 13 states said they would be checking eligibility requirements after they’ve made the reimbursement payments. Eleven of these states plan to start audits in 2011, one state in 2012, and the last state had no timeframe for when they would start their audits.
So, what will most states not be looking for?
According to the study, there are three eligibility requirements that the majority of these states will not look for, primarily because they haven’t been collecting the necessary data.
Here’s what might be missing:
- Practitioners must have at least 30% needy individual patient volume if they are practicing predominantly in an FQHC or RHC.
- If a practioner is a PA, he or she must practice in a PA-led FQHC or RHC.
- Practitioners and hospitals must adopt, implement or upgrade an EHR.
Of these three eligibility requirements, 10 states will not be checking the first, 9 states won’t check the second, and 8 states won’t check the third.
The good news is that the study does offer some insight into what states will be verifying. One requirement that almost all states will partially or fully verify is this:
- Practitioners must have at least 30% Medicaid patient volume (or 20% for pediatricians) if they are not practicing predominantly in an FQHC or RHC.
So, what does all this mean for your clinic?
Well, although this study doesn’t, of course, cover all 50 states, it does offer some insight into what might happen when verification times come. All clinics should strive for 100% eligibility, since that’s the right thing to do. However, you might have more time than you think to get your clinic in shape, since many states won’t start the verification process later on down the road.