American Osteopathic Association

Advancing the distinctive philosophy and practice of osteopathic medicine

Meaningful Use FAQs

1. Meaningful Use is a Centers for Medicare & Medicaid (CMS) program, so do I only have to chart Medicare/Medicaid patients?

The Electronic Health Records (EHR) Incentive Program, also known as the “Meaningful Use” program is based on all patients you see in your practice. The objectives that depend on continuous actions are based on “all unique patients” seen during the indicated reporting period. Since the goal of the program is to use an EHR to deliver better care, it makes sense that Meaningful Use pertains to your entire practice, regardless of patient insurance status.

2. Do I have to submit proof of my attestation? What documents should I retain after I complete attestation?

Attesting to Meaningful Use follows the logic of affirming that something is true. After you have achieved all the required criteria, submit your results for the meaningful use objectives and clinical quality measures on the CMS website. You must keep documentation (in paper or electronic format) supporting all of the information you attested to in case you get audited. Documentation to support attestation data for meaningful use objectives and clinical quality measures should be retained for six years post-attestation. Documentation to support payment calculations (such as cost report data) should continue to follow the current documentation retention processes.

3. How do I determine when I will begin Stage 2 of Meaningful Use?

You will begin Stage 2 reporting in your third year of demonstrating Meaningful Use. Access the CMS Meaningful Use Stage 2 Guide for additional information.

4. Do I need to bill a certain amount of services to Medicare or Medicaid to qualify?

There is no minimum dollar amount you need to bill in order to be eligible for the Medicare EHR Incentive Program; however, you must treat Medicare patients and bill for Part B services under the Physician Fee Schedule. In addition, only certain types of health care providers are eligible for the program (called “eligible professionals”).

Eligibility for the Medicaid EHR Incentive Program depends on the EP meeting a certain patient volume. If you meet the 30% Medicaid patient volume (20% for Pediatricians) threshold for a given year, you may be eligible to qualify for an incentive payment.

Hospital-based eligible professionals are not eligible for incentive payments. An eligible professional is considered hospital-based if 90% or more of his or her services are performed in a hospital inpatient (Place of Service code 21) or emergency room (Place of Service code 23) setting.

Visit the EHR Incentive Program website to learn more about eligibility, payments and requirements.

5. How does sequestration affect incentive payments for the Meaningful Use program?

EHR incentive payments under the Medicare program will be subject to a 2% reduction due to the Budget Control Act of 2011, also known as sequestration. The 2% reduction will apply to any payment for the 2013 reporting year and after (i.e. any reporting period end date on or after April 1, 2013). Medicaid incentive payments are not subject to reductions.

Since the sequestration is an across-the-board spending reduction, all Medicare Fee-for-service (FFS) claims on or after April 1, 2013, will be subject to a 2% reduction.

6. Does the maximum incentive payment amount apply to each practice or each individual provider?

The Meaningful Use incentive payments are paid to each eligible provider who successfully attests. If you have more than one eligible provider in a practice, they can all demonstrate Meaningful Use and earn an individual incentive payment.

7. If a practice is owned by the hospital, who gets paid under the EHR Incentive Program?

This depends on how you normally receive Medicare or Medicaid reimbursements. You will be able to select the incentive payment designation for Meaningful Use during registration on the CMS website. The payment will be made to the taxpayer identification number selected during registration through the same channels your claims payments are made.

8. Does everyone in my office, specifically support staff, need to participate in the EHR Incentive Program if I am aiming for the Meaningful Use incentive payment?

Successfully meeting the requirements of the EHR Incentive Program is based upon an eligible professional meeting all the requirements for the patients they see. The office staff members are not required to meet Meaningful Use themselves. However, since Meaningful Use is a collective effort, clinician staff is most likely going to play a role in recording patient information in the EHR for the eligible professional qualifying for the incentive. Similarly, it is not necessary for all providers who practice in the same setting to participate in the EHR Incentive program in order for an individual eligible professional within that practice to satisfy the requirements.

9. What if some of the Meaningful use criteria do not relate to my specialty or practice?

If a Meaningful Use objective does not relate to your scope of practice, you may qualify for an exclusion. Exclusions are CMS regulatory-specified exemptions from completing certain criteria and can be claimed during attestation. If you qualify for an exclusion, you do not need to demonstrate Meaningful Use for that particular measure and you can still receive a full incentive payment.

You will not need to submit any proof to claim an exclusion during attestation. However, you need to be prepared to prove your qualifications for an exclusion in case of an audit. Review the CMS measures to learn about specific exclusions.

10. How do I choose which menu measures to complete?

In order to successfully attest to Stage 1 of Meaningful Use, you must report on five menu measures from the full menu set, and you must choose at least one from the public health menu set: 

  • Menu Measure 9: Immunization registry data submission

  • Menu Measure 10: Syndromic surveillance data submission

If you are able to meet one public health menu measure but can be excluded from the other, then you should report on the public health menu measure you are able to meet.

If you are excluded from both public health menu criteria, you should claim an exclusion from only one public health option and report on four additional menu criteria from outside the public health menu set.

CMS encourages providers to select menu criteria that are relevant to their scope of practice and claim an exclusion for a menu measure only in cases where there are no remaining menu measures that are relevant to their scope of practice.

11. If I complete all measures before my reporting period ends, can I attest?

No, you must complete your reporting period before attesting to CMS. Meaningful Use is based on all the patients you see during the timeframe of your designated reporting period.

12. Are physicians who work in hospitals eligible?

You may be considered an “eligible professional” with regards to participation in the EHR Incentive Program even if you work in a hospital. According to CMS, physicians who furnish substantially all, defined as 90% or more, of their covered professional services in either an inpatient (POS 21) or emergency department (POS 23) of a hospital are not eligible for incentive payments under the Medicare and Medicaid EHR Incentive Programs. In other words, if more than 10% of your services are in the outpatient setting, you can qualify to participate in the EHR Incentive Program as an individual. See the "Hospital Physician" CMS FAQ for more information.

13. Do I need to incorporate patients I see in the hospital in my clinic EHR?

If a provider sees patients in inpatient and outpatient settings, the provider should base both the numerators and denominators for Meaningful Use objectives on the number of unique patients in the outpatient setting, since this setting is where one is eligible to receive payments from the EHR Incentive Programs. See the Inpatient vs. Outpatient CMS FAQ for more information.

14. Does Medicaid as a secondary insurance count for the eligibility volume?

The Medicaid patient volume methodology will be designated by your state Medicaid agency and approved by CMS. In determining patient volume thresholds, you should include patients enrolled in your state’s Medicaid program (either through the state’s fee-for-service programs or the state’s Medicaid managed care programs) at the time of service without the requirement of Medicaid payment liability. In other words, Medicaid does not need to pay for the encounter to include the patient when determining eligibility. 

ABOUT THE AUTHOR: The information in this section was written by Naushad Godrej. Mr. Godrej is a Senior Meaningful Use Specialist at Practice Fusion who has a passion for health policy and the practical applications for information technology. He has helped thousands of physicians and practitioners with the resources they need to improve patient care through the EHR and PHR. In his role, Mr. Godrej answers a volume of questions he receives daily from medical users and has shared his knowledge with the AOA.


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