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

Hospital-based status is based only on Medicaid inpatient/ emergency room claims. You can be eligible even if you work/ worked in a hospital!

The letter for hospital-based status IS NO LONGER REQUIRED, effective immediately. The HIT Division will base hospital-based status ONLY on the EP’s individual Medicaid claims by reviewing reports produced by SCDHHS – employment history is not considered in this determination. Only those claims that occurred in an inpatient hospital (POS 21) or an emergency room (POS 23) will count toward the percentage. And the review of claims history is separate for each year.

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.



If a provider 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)  but who can demonstrate the following may be determined to be a nonhospital-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, incentives are paid up to $63,750 per provider.

The SLRis accepting attestations for program year 2017 through June 30th 2018.

The HIT Division recognized that the letter placed a burden on providers and has made many other changes to expedite the attestation and payment process. Thank you for your participation, we look forward to serving you in the future.

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