Electronic Health Record EHR
Incentive Program and PAs
Eligible Professionals
PAs and NPs are not considered eligible professionals under the Medicare EHR Incentive program. Under the Medicaid program, PAs are eligible in limited circumstances (in PA-led RHCs and FQHCs). Physicians are eligible under both the Medicare and Medicaid programs. Nurse practitioners are fully eligible under the Medicaid program.
For complete details about practitioner eligibility for both the Medicare and Medicaid EHR Incentive programs, go to the CMs website http://www.cms.gov/EHRIncentivePrograms/.
Medicaid EHR Incentive
Physician assistants are eligible for the Medicaid EHR incentive when working at an FQHC or certified RHC that is so led by a physician assistant. In response to comments, CMS clarified “so led” to mean:
- When a PA is the primary provider in a clinic; (for example, and RHC with a part-time physician and a full-time PA would be considered “PA-led”)
- When a PA is a clinical or medical director at a clinical site of practice; or
- When a PA is an owner of an RHC.
Additionally, for the Medicaid incentive, there is a percentage volume requirement. Eligible Professionals must have a minimum of 30% of their visits as unique encounters. Pediatricians may have 20%.
Medicaid incentives are administered by State agencies. Click here to download a Contact List.
Regional Extension Centers
The HITECH Act authorizes a Health Information Technology Extension Program to support and serve health care providers to help them quickly become adept and meaningful users of electronic health records (EHRs). Regional Extension Centers (RECs), designed to make sure that primary care clinicians get the help they need to use EHRs, will focus their most intensive technical assistance on clinicians (physicians, physician assistants, and nurse practitioners) furnishing primary-care services, with a particular emphasis on individual and small group practices (fewer than 10 clinicians with prescriptive privileges). Clinicians in such practices deliver the majority of primary care services, but have the lowest rates of adoption of EHR systems, and the least access to resources to help them implement, use and maintain such systems. Regional Extension Centers will also focus intensive technical assistance on clinicians providing primary care in public and critical access hospitals, community health centers, and in other settings that predominantly serve uninsured, underinsured, and medically underserved populations.
For more information, go to the Office of the National Coordinator’s website, where you will also find a list of the Regional Extension Centers.
Rules
In response to CMS proposed rules regarding the EHR incentive program, published early in 2010, , the AAPA put out a call for action to the membership entitled “Rule to Make PAs Eligible for EHR Incentive Payments”.
Comments Urged on CMS Proposed Rule to Make PAs Eligible for EHR Incentive Payments Physician Assistants are urged to provide comments by no later than March 15th on a proposed rule from the Centers of Medicare and Medicaid Services (CMS) implementing the provisions of the American Recovery and Reinvestment Act of 2009 (ARRA) (Pub. L. 111–5) that provide incentive payments to eligible professionals (EPs) and eligible hospitals participating in Medicare and Medicaid programs that adopt and meaningfully use certified electronic health record (EHR) technology. AAPA has some serious concerns that if not appropriately clarified could severely limit these incentives for PAs to help expand access to care for some of the most medically underserved patients in the country.
PAs are encouraged to review AAPA’s comments on the proposed rule and submit their own comments to CMS using local examples to help reinforce the Academy’s concerns. PAs can view the proposed rule and click on “submit comment” to electronically offer their input on the proposed regulations.
CMS responded to AAPA’s comments by stating that the incentive is based in law (ARRA 2009), and, as such, cannot be amended by rule-making. Thus, the law itself requires changing-literally an Act of Congress. This was highlighted in the August 2010 PA Professional article, “Final Rules on Bonus Payments for EHRs Issued” by Ashley Kent.
Click here to download text of article Final Rules on Bonus Payments for EHRs Issued
Next Steps
AAPA is attempting to rectify the situation with federal legisltion. Watch for Action Alerts and updates in AAPA’s “PA Advocate” e-mails, distributed to AAPA members weekly.
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