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What is Hospital-Based? A Letter is No Longer Required!

Hospital-based status is based only on Medicaid inpatient (POS 21)/ emergency room claims (POS 23). You may be eligible even if you work/ worked in a hospital!

The letter for hospital-based status IS NO LONGER REQUIRED. The HIT Division based hospital-based status on the EP’s individual Medicaid claims by reviewing reports produced by SCDHHS. The HIT Division reviews the Eligible Professional's total inpatient hospital (POS 21) claims and combines them with their total emergency room (POS 23) claims and divides that figure by the remaining claims which occurred in the calendar year which occurred prior to the program year they are attesting for. If the percentage of percentage of POS 21 and POS23 claims is 90% of more, the provider is considered hospital-based and ineligible to receive an incentive payment. The review of claims history is performed each time a provider submits and attestations and may change - therefore, the provider's may be eligible in some program years but not for others.

Note: you will not be able to confirm your hospital-based status from CMS for the Medicaid EHR Incentive Program – Medicare claims are not used to determine your status and are not considered. You can therefore be considered hospital-based in the Medicare Incentive program and considered NOT-hospital based in the Medicaid Incentive Program.

We have also become aware that a provider may not attest because they do not know their hospital-based status or make an incorrect assumption about their status. There is no penalty for attesting if you are unsure. A provider is NOT considered hospital based solely because they work or worked in a hospital(s) – employer information is NOT considered in this determination.

Question: If a EP performs 90% or more of their Medicaid covered professional services in an inpatient (POS 21) or emergency room (POS 23) , can they still qualify to receive an incentive payment?

  An EP who initially meets the definition of hospital-based EP with greater than 90% of their visits having taken place in in an inpatient (POS 21) or emergency room (POS 23) is considered hospital-based. However, if the EP can demonstrate the following, then they may be determined to be a not hospital-based EP by the HIT Division:

  1. The EP funds the acquisition, implementation, and maintenance of Certified EHR Technology, including supporting hardware and interfaces needed for meaningful use without reimbursement from an eligible hospital, and
  2. The EP uses such Certified EHR Technology in the inpatient or emergency department of the hospital (instead of the hospital's Certified EHR Technology) 

If the above is applicable, please contact the HIT Division as soon as possible for more information, or with questions. Don’t assume you are not eligible.

The SLR is accepting attestations for program year 2018 through March 31, 2019.

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