As an Anesthesiologist, What Should I Do About Meaningful Use if I am a Medicaid Provider?

The EHR Incentive Program, often dubbed "Meaningful Use", has been surrounded by questions and confusion among anesthesiologists and practice administrators since its inception.  Currently, the majority of anesthesiologists and pain physicians are classified as an Eligible Professional (EP) under the Medicare portion of Meaningful Use and most of the public conversation is centered on that program.  However, the Medicaid option offers more flexibility and financial incentive which raises the question, "How does the Medicaid EHR Incentive Program differ from the Medicare portion?"

The major differences between the Medicare and Medicaid programs of Meaningful Use center on:

* Provider Eligibility
* Provider Enrollment
* Financial Incentive
* Attestation Schedule

Provider Enrollment and Eligibility

To be considered a Medicaid EP, an anesthesiologist or pain physician must perform less than 90 percent of their services in an inpatient setting (POS 21), but also must provide at least 30% of services to Medicaid patients.  According to CMS:

Medicaid patients might be fee-for-service encounters where the State Medicaid Agency pays you for your services (this includes primary care case management and medical home programs). Also, it might mean that you see patients through a state’s Medicaid managed care program (i.e., you are a network provider for a managed care organization contracted to provide Medicaid services). Please contact your State Medicaid Agency about this and for more information about calculating the patient volume with precision.

The only threshold required for the Medicare Meaningful Use program is that the provider had at least one encounter with a Medicare patient.  The above requirement excludes a majority of anesthesia and pain physicians but if you find that your patient mix reflects 30 percent or more of Medicaid patients, that program might be the better choice for your group.

Unlike the Medicare EHR Incentive Program, Medicaid Meaningful Use is administered by the states.  The process to enroll, register, and attest is more complicated given that each state has flexibility in how to maintain the program, but they all follow a basic format.  As with the Medicare MU program, the anesthesiologist or pain physician has the option to perform all the necessary steps to register and attest, or to delegate this work to another party such as a practice administrator.  Regardless of the person entering the information, the provider must be enrolled on the CMS website ( and have an active NPI number.

After completing all initial registration steps on the CMS site, the user must enter the Medicaid State and EHR Certification Number of the software technology that has been implemented at their facility. There is no requirement as to whether the physician must own the EHR software package, but one must be adopted before the provider can begin either incentive program.

For certification information on your EHR technology, navigate to: and perform a search on the Office of the National Coordinator for Health Information Technology website.

After all the steps have been completed on the CMS website, the provider must then wait for the individual state MU program to validate the registration. Each state has its own MU website and implementation timeline. To look up your state’s information, review the PDF maintained at

Financial Incentive

Under the Medicare MU program, EPs are eligible to receive a maximum incentive payment of $44,000 over 5 years. The Medicaid MU program outlines a maximum of $63,750 over 6 years.  Additionally, the Medicare MU program identifies a reduction in reimbursements if a certified EHR technology has not been implemented by 2015. The Medicaid program does not penalize the provider with a payment reduction if a certified EHR technology hasn’t been implemented by 2015. However, if the provider performs services on both Medicare and Medicaid patients, they will see the payment adjustment in 2015 for all Medicare patients if an EHR technology hasn't been adopted by 2015.

The incentive payment schedule for EPs under Medicaid differs from Medicare as follows:

Attestation Schedule

One of the most important distinctions between the two Meaningful Use programs is around the attestation schedule.  Currently under Medicare MU, EPs must attest to meeting all the objectives in Stage 1 of that program.  As has been discussed at length by the American Society of Anesthesiologists (ASA), ABC, and other organizations, the objectives outlined by CMS are largely impractical for anesthesiologists to attest to.  However, the Medicaid program does not require that EPs demonstrate Meaningful Use in the first year.  States do have the flexibility to require this, but at this point no state has enforced this option.

Medicaid EPs must Adopt, Implement, or Upgrade (AIU) a Certified EHR in the first year.  According to the schedule outlined above, that entitles the provider to an incentive payment of $21,250 for only installing the EHR technology.  Starting in the second year, the Medicaid EPs will need to follow the standard path of attestation that the Medicare program follows.  Specifically, they will need to attest to all the objectives of the MU program for a reporting period of 90 days.  In year 3 and on, the full year will need to be reported.

It is recommended that all anesthesiologists and pain physicians review their patient mix and register on the CMS site for the EHR Incentive Program whether you have a Certified EHR technology in place or not.  The registration process can be time consuming and if the opportunity presents itself that you can proceed with either incentive program, it will be all the easier to move forward.

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