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Five key questions about EHR incentive funds

April 28, 2011
by Dennis Grantham, Editor-in-Chief
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The latest on EHR certification and “eligible provider” qualification

Congress allocated funds, about $20 billion, in the HITECH section of the ARRA to encourage and incentivize health care providers to adopt and “meaningfully use” electronic health records. There are two programs of incentive funding, one for Medicare providers and a second for Medicaid providers.

1) What are the EHR incentives intended for?
“Some people think that the incentives are intended to buy the EHR software itself,” says Kevin Scalia, Executive Vice President at Netsmart Technologies. That’s wrong, he asserts, noting that “the incentives are for demonstrating that you’re meaningfully using an EHR within your organization. To do that, you’ve not only got to acquire-implement-or upgrade to a “certified” EHR (the official list is found at but get your organization using it, and attest to that use for a 90-day period, according to the requirements.”

2) Who certifies EHRs? What criteria do they use? EHR certification is performed by Authorized Testing and Certification Bodies, otherwise known as ATCBs. EHR developers must submit their EHR software to these testing bodies, along with a fee, to start the certification process. All ATCBs use the same test criteria. Upon successful completion of the certification test, the EHR is referred to as “certified” or “ATCB certified.”

On the website, ATCB-certified EHRs are typically grouped into two categories: “ambulatory” or “inpatient.” Within each category, there will be two types of EHRs listed, based on the type of certification they receive: “complete” or “modular.
3) What’s the difference between a “complete” EHR certification and a “modular” EHR certification? The EHR certification process provides two types of certification for EHRs: “Complete” and “Modular.” An EHR certified as “complete” is one that has been developed and is certified to meet to meet, at a minimum, all applicable certification criteria adopted by the Secretary of HHS. Complete EHRs typically fall into two categories: EHRs for ambulatory settings and EHRs for inpatient settings. You will see these categories on the ONC-CHPL website noted above.

  • Complete EHRs that are certified for an ambulatory setting meet the certification criteria adopted at 45 CFR 170.302 and 45 CFR 170.304.
  • Complete EHRs that are certified for inpatient settings meet all of the certification criteria adopted at 45 CFR 170.302 and 45 CFR 170.306.

These “complete” certification criteria represent the minimum capabilities EHR technology needs to include and have properly implemented in order to achieve certification. They do not preclude complete EHR developers from including additional capabilities that are not required for the purposes of certification.

“Modular” certification is granted to any service, component, or combination of these (an EHR module) that meets ATCB testing requirements for one or more, but not all, of the certification criteria that have been adopted by the Secretary of HHS.

By definition, EHR modules are pieces of EHR functionality that must stand alone for functional testing purposes, but which must be combined with other certified “modules” in order to have a single EHR that can support the complete set of Meaningful Use criteria.

Unique combinations of certified EHR modules require ATCB certification as a “complete” EHR before they can, together, qualify as an EHR. Often, these combinations are submitted for testing by software vendors, but organizations may also submit their own, locally developed EHR systems for certification.

4) Who qualifies for EHR funds? If you heard that behavioral health providers got the short end of the stick when it comes to HITECH EHR incentives, you’re half right. At present, licensed clinical social workers do not qualify for EHR incentives, nor do behavioral health organizations including inpatient psychiatric hospitals and addiction treatment centers.

However, physicians and nurse practitioners who work in behavioral health organizations (as well as physician assistants who work in Federally Qualified Health Centers), can qualify as eligible providers if they meet individual encounter criteria (a minimum of 30 percent Medicaid encounters) and use a certified EHR.

5) What’s the newest way to qualify eligible providers?
Some providers are choosing to qualify eligible providers with a new method, called a “clinic volume proxy.” This calculation is suited to organizations where providers (physicians and nurse practitioners) see relatively similar groups of patients, but when not all providers would otherwise meet the individual encounter (30 percent Medicare encounters) criteria.

For an excellent discussion on the clinic volume proxy, as well as other aspects of meaningful use, consult the CMS website answers section, found at, or review the April 13 webinar given by Kevin Scalia of Netsmart Technologies, which is available under the Behavioral Healthcare webinars tab at

6) Is there Congressional action to expand EHR incentives? The Behavioral Health Information Technology Act of 2011 (S. 539), introduced by Sheldon Whitehouse (D-RI), would address limitations of the ARRA HITECH Act for behavioral healthcare by: