Medicaid EMR guidelines spell out state help for doctors

Washington -- The Centers for Medicare & Medicaid Services has published details for state Medicaid directors on what they should expect from the federal government as they administer the Medicaid portion of the electronic medical records incentive program starting in 2011.

The incentive program stipulates that the federal government will pay the full cost of Medicaid bonuses to eligible physicians who adopt certified EMR technology in a way that meets the government's "meaningful use" criteria. It also will pay 90% of states' eligible administrative expenses. Aspects of the latter have been a source of particular confusion for state agencies, which is why CMS chose to issue the additional guidance on Aug. 17, according to policy experts familiar with the incentive program.

"Time is growing short, and I think they were worried that some states hadn't moved forward quickly enough," said Erica Drazen, managing partner for Emerging Practices, a professional services organization based in Falls Church, Va. "It wasn't like there was a lot of detailed guidance on this subject before. There needs to be consistency among the states."

According to the new CMS guidance, states must satisfy at least three basic requirements to receive the federal funding: administer Medicaid bonuses to eligible physicians and hospitals, routinely track meaningful use reports and conduct other oversight activities, and pursue initiatives that encourage EMR adoption to promote health care quality.

The 19-page document provides additional details on what the agency is looking for from the states. For example, under the administration section, CMS says states will receive 90% funding for:

• Development of a master patient index.
• Costs associated with health information exchanges.
• Creation or enhancement of a health data warehouse or repository.
• Physician outreach activities, including workshops, webinars and meetings.
• A physician help line, dedicated e-mail address and/or a call center.

CMS also is expecting states to implement auditing programs to help prevent them from making improper Medicaid bonus payments and to monitor the program for potential fraud, waste and abuse. For 2011, the first year of the incentive program, the agency expects states to focus audits on physician and hospital eligibility and measures of patient volume.

States may receive enhanced federal matching funds for auditing activities focused on enrollment, license verification, sanctions, data analysis, and privacy and security.

Drazen said the guidance is appreciated and has been well-received by most state offices. "There's a lot going on, and it can get a little confusing about what you can do and when."

Bruce Taffel, MD, agrees. He's vice president and chief medical officer with Shared Health, a vendor of health information exchange solutions and technology based in Chattanooga, Tenn. "With the states, you're going to have 50 different flavors, so what CMS came out with is an important step in coordination and outreach, because the states are going to have to hustle."

Dr. Taffel said it was particularly important for CMS to consider state incentive models such as medical homes as acceptable criteria for federal funding, since many states already use such programs. With the agency recognizing medical homes, it's more likely that physicians operating within them will be able to receive incentive payments of their own, he said.

Under the bonus program, physicians whose caseloads are at least 30% Medicaid patients and who also adopt certified EMRs by 2011 or 2012 are eligible for up to nearly $64,000 in support over a period of six years.

By comparison, Medicare-participating physicians who adopt certified EMRs could receive up to $44,000 over five years. Doctors cannot receive both Medicare and Medicaid bonuses.

CMS issued its final rule outlining meaningful use requirements on July 13. The Office of the National Coordinator for Health Information Technology also issued a final rule the same day outlining the standards and criteria EMR vendors need to follow for their products to become certified for meaningful use.