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Who is eligible to receive EHR Incentive Program payments?

CMS provides details on the eligibility requirements for individuals for each of the EHR Incentive Programs. Eligible providers (EP), including dentists, can qualify to receive incentives from either  the Medicare or Medicaid EHR Incentive programs although dentists are more likely to participate in the Medicaid program. Specifically, CMS considers the following eligible professionals under the Medicare EHR Incentive Program:

• Doctor of medicine or osteopathy
• Doctor of dental surgery or dental medicine
• Doctor of podiatry
• Doctor of optometry
• Chiropractor

Under the Medicaid EHR Incentive Program, eligible professionals are defined as:

• “Physicians (primarily doctors of medicine and doctors of osteopathy)
• Nurse practitioner
• Certified nurse-midwife
• Dentist
• Physician assistant who furnishes services in a Federally Qualified Health Center or Rural Health Clinic that is led by a physician assistant.”

While dentists are eligible to qualify to receive incentives from either the Medicare and Medicaid EHR Incentive Programs, almost no dental services are covered by Medicare.  As a result, most dentists will only be eligible to receive incentive payments from the Medicaid Meaningful Use incentive program.  Any EP, including dentists, qualifying for incentives under the Medicaid program must meet the criterion that “the EP must have at least 30 percent patient volume attributable to those who are receiving Medicaid”.  While pediatricians are able to receive incentive payments with only 20 percent of their patient volume attributable to Medicaid, this does not apply to pediatric dentists, who are still responsible for attesting to the 30% Medicaid patient volume threshold in order to receive payments.  Similar to other EPs, dentists practicing predominately in a Federally Qualified Health Center (FQHC) or rural health center (RHC) can receive incentives if they can attest that at least 30% of patients can be classified as “needy individuals”. Needy individuals are defined in the Final Rule by the following three criteria: 1. Receives medical assistance from Medicaid or the Children’s Health Insurance Program (CHIP); 2. Receives uncompensated care by the provider; or 3. Receives services at either no cost or reduced cost based on sliding scale determine by the individual’s ability to pay.