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Provider FAQs

EHR FAQs for Providers

These FAQs are to provide current information on Oregon's program. If you cannot find the answer to your question, please send an e-mail to New questions and answers will be posted periodically on this website. Subscribe to receive email alerts when we make updates to this site.

Providers need to register with the Centers for Medicare and Medicaid Services (CMS) and then apply with Oregon. Information on the steps needed to apply is available

Watch an information webinar about the steps to take to register and apply. For more information on what you need to do to prepare for registration with CMS, see this Registration User Guide. CMS has an informative youtube video that will walk you through the steps to register:

  1. Eligible professionals that are participating in the Medicaid EHR Incentive Program for the first time in 2012 have 60 days after the end of the program year to apply for an incentive payment. March 1, 2013 is the last day to apply for a 2012 year one payment.

  2. Eligible professionals participating in their second year in the Medicaid EHR Incentive Program for 2012 have 90 days after the end of the program year to apply for an incentive payment. March 31, 2013 is the last day to apply for a 2012 year two payment.

Most applications are requiring some additional clarification or documentation from applicants. Therefore, you should anticipate getting a communication from us asking for some additional documentation. We understand that there has been some confusion about the timing of processing of applications and payments. Once your application has been completely reviewed, you have provided any necessary supplemental documentation, and your application is approved, you will then receive your payment within 45 days of approval.

Complete EHRs and EHR modules are required to be certified through an Authorized Testing and Certified Body (ATCB) designated by the Office of the National Coordinator (ONC). Before ONC established ATCBs, Certification Commission for Health Information Technology (CCHIT) had its own certification process for EHR technology. CCHIT has now become an ATCB and can certify EHR technology that meets ONC's ATCB certification. CCHIT certified products prior to becoming an ONC-ATCB do not qualify as certified for the Incentive Programs.

Visit our EHR Support page for details.

The Medicare and Medicaid EHR Incentive Programs have different requirements for eligible professionals. The CMS Eligible Professional Flow Chart can assist in determining eligibility. See full list and more information at our Provider Eligibility page.

No, Oregon Medicaid policy does not include optometrists as providing Medicaid physician services.

Federally Qualified Health Centers (FQHCs) are "safety net" providers such as community health centers, public housing centers, outpatient health programs funded by the Indian Health Service, and programs serving migrants and the homeless. The main purpose of the FQHC Program is to enhance the provision of primary care services in underserved urban and rural communities.

RHCs (Rural Health Centers) are clinics that are certified under section 1861(aa)(2) of the Social Security Act to provide care in underserved areas, and therefore, to receive cost-based Medicare and Medicaid reimbursements.

In considering these definitions, it should be noted that programs meeting the FQHC requirements commonly include the following (but must be certified and meet all requirements stated above): Community Health Centers, Migrant Health Centers, Healthcare for the Homeless Programs, Public Housing Primary Care Programs, Federally Qualified Health Center Look-Alikes, and Tribal Health Centers.

Medicaid-eligible professionals may not be hospital-based. A Medicaid eligible professional (EP) is considered hospital-based if 90% or more of the EP's services are performed in a hospital inpatient (place of service code 21) or emergency room setting (place of service code 23). This provision does not apply to providers who practice predominantly in an FQHC/RHC.

"So led" is defined in federal rule by CMS to be one of the following:
  1. When a PA is the primary provider in a clinic (e.g., when there is a part-time physician and full-time PA, the PA is considered to be the primary provider).
  2. When a PA is a clinical or medical director at a clinical site of practice.
  3. When a PA is an owner of an RHC.

Information on patient volume/patient threshold requirements is on our Provider Eligibility page.

Part of the application process for the Medicaid EHR Incentive Program requires the applicant to provide and attest to their patient volume data. We understand that this might be a challenge for some providers, particularly if they are still in the process of moving from paper to an EHR, but compiling that information is part of the application process. The Medicaid EHR Incentive Program staff is not able to provide patient data to providers to use in their applications. Data sources used to support patient volume attestations are required to be retained for seven years.

The maximum payment to pediatricians who have at least 20% Medicaid patient volume but less than 30% will receive 2/3 of the maximum Medicaid EHR incentive payment; $42,075 over the course of six years of participation in the program. Pediatricians who have at least 30% Medicaid patient volume will receive the maximum Medicaid EHR incentive payment of $63,750 over six years.

Needy individuals include all the following:
  • Person who is receiving assistance under Title XIX (Medicaid);
  • Person who is receiving assistance under Title XXI (CHIP); 
  • Person who is furnished uncompensated care by the provider; 
  • Person for whom charges are reduced by the provider on a sliding scale basis based on the individual's ability to pay
For more information on the role of "needy individuals" in determing patient volume calculations go to the Provider Eligibility page.

A Medicaid encounter means:
  • Services rendered on any one day to an individual where Medicaid paid for part or all of the service or,
  • Services rendered on any one day to an individual where Medicaid paid for part or all of the premiums, co-payments, and/or cost-sharing.
Separate visits paid under one bundled payments can be counted separately.

For example, if a patient had 13 office visits on different days but payments for all visits were bundled into one lump sum payment:
  • Any of the 13 visits paid in part of whole by Medicaid would be counted in the numerator.
  • All 13 encounters would be counted in the denominator.

Yes, if Medicaid paid part or all of the service being rendered to an individual on any one day they may be counted as a Medicaid encounter.

No, the patient volume thresholds of 30 percent and 20 percent (pediatricians) are required by federal statute and cannot be changed by states.

The incentive payments are made on a per eligible professional (EP) basis. If you are part of a practice or clinic, the patient volume may be calculated on a group level which means the encounters for all practitioners (eligible and non-eligible providers) in a group practice are used to determine patient volume. After the first year of participation each EP will need to individually demonstrate meaningful use of certified EHR technology. In addition, each EP is eligible for one incentive payment each year, regardless of the number of practices or locations.

In the first year of the program, Oregon will offer providers the choice of calculating patient volume using either the Patient Encounter or Patient Panel methodology. Both methods require providers be able to properly document their patient volume.

Further, project staff is interested in ideas for an alternate methodology that would allow additional providers to meet the 30% (20% for pediatricians) patient volume requirements. Any alternate methodology must be approved by CMS prior to use by a state.

Patient Encounter Method

Total Medicaid (or Needy Individual*) patient encounters**
Total patient encounters**

Patient Panel Method

Total Medicaid (or Needy Individual*) patients assigned to the provider** with at least one encounter in the prior year
Unduplicated Medicaid (or Needy Individual*) encounters**

Total patients assigned to the provider** with at least one encounter in the prior year
Unduplicated encounters**

*For providers who practice predominantly in a FQHC/RHC, use "Needy Individual" which includes Medicaid along with other individuals.
**In any representative continuous 90-day period in the preceding calendar year.
Unduplicated means: a patient counted as assigned to a provider that also had an encounter should only be counted once in the calculation.

Yes, Oregon will include out of state Medicaid patient encounters in the patient volume calculation.

An eligible professional can receive up to $63,750 over the course of six years.

​Eligible professionals (EP) can receive payments for up to six years; payment years do not need to be consecutive. EPs must initiate participation no later than 2016. See our Provider Incentive Amount page for a table of payment examples.

No, an eligible professional who is eligible for both the Medicare and the Medicaid EHR Incentive Programs can only participate in one program, not both. During the registration process, eligible professionals need to select either the Medicare or Medicaid EHR Incentive Program.

Before 2015, an eligible professional may switch between the programs one time after the first incentive payment is initiated.

In year one of participation in the Medicaid Electronic Health Record (EHR) Incentive Program, providers do not need to meet meaningful use reporting requirements. Rather, providers will attest to the adoption, implementation or upgrade (AIU) of certified EHR technology.

Eligibility in year one of the program requires the adoption, implementation, or upgrade (AIU) to certified EHR technology. CMS is requiring that Oregon validate this eligibility criterion by verifying at least one of the four following types of documentation:
  • copy of a software licensing agreement
  • contract
  • invoices
  • receipt that validates your acquisition
Vendor letters, and other documents may also be submitted as a supplement to the items on the documentation list above. However, these supplemental documents will not satisfy program eligibility requirements on their own.
  • Adopt: Acquire, purchase, or secure access to certified EHR technology
  • Implement: Install or commence utilization of certified EHR technology capable of meeting meaningful use requirements
  • Upgrade: Expand the available functionality of certified EHR technology capable of meeting meaningful use requirements at the practice site, including staffing, maintenance, and training, or upgrade from existing EHR technology to certified EHR technology per the ONC EHR certification criteria. For more information on Meaningful Use Implementation please go to the Provider Meaningful Use page.