July 22, 2010

CMS Recognizes That a 30% Medicaid Encounter Rate is a Rarity?

Filed under: CMS,EHR Incentive — Tags: — HankMayers @ 10:22 pm

The 1/13/10 draft Medicaid EHR Incentive required that an eligible practitioner (EP) have atleast 30% of its encounters be “attributable to Medicaid” in any 90 day quarter of the reporting year. Most physicians that I have talked with on this subject say this is a game-killer, as 30% Medicaid is the point where conventional wisdom holds that a practice starts becoming insolvent. This Medicaid EHR incentive requirement has always struck me as a major flaw or hole in the EHR incentive “balloon”.

It would seem, from a reading of the final regs, that CMS has taken a step to reduce the risk from this particular requirement, by adding a 2nd calculation method. The final reg allows a state (such as Michigan), in which Medicaid enrollees are assigned to managed care programs, to allow the EP to count the total assigned Medicaid managed care panel (or from other Medicaid assigned patient programs), PLUS all other Medicaid encounters during the reporting 90 day period. There is an acceptable proxy to this numerator calculation in which “an encounter with any [Medicaid] patient on the panel within the previous calendar year prior to the representative 90-day period when the patient was on the panel.” In all cases, the EP is not allowed to count any Medicaid patient more than once in the reporting quarter.

The intent, apparently, is to allow the EP to count any Medicaid patient in its panel as an encounter, plus any non-panel Medicaid patient encounters. It would seem that this is an advantage IF non-Medicaid patients generate much less frequent encounters.

Regretably, the state Medicaid program offices will not have ready data on this prospect, because indivdual service claims are not filed in managed care programs.

So, I am asking my practitioner friends to comment and let me know if they think this arrangement will help them achieve Medicaid EHR incentive eligibility!.

Thanks, everyone

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