The basic eligibility requirements remain the same, regardless of stage of participation. That is, the Medicare program for eligible professionals only applies to physicians, dentists or dental surgeons, podiatrists, optometrists and chiropractors who are not hospital-based. Non-physician practitioners and other members of the care team are not eligible for incentive payments under this program. All requirements regarding the percentage of patient encounters at locations using certified electronic health records (EHRs) also remain the same.

The only area of change pertaining to eligibility applies to the eligibility of physicians meeting the definition of hospital-based. As part of the Stage 2 rulemaking process, the Centers for Medicare and Medicaid Services (CMS) agreed to change the regulations to allow eligible professionals who might otherwise be considered hospital-based to fall outside of that definition if they demonstrate that they fund the acquisition, implementation and maintenance of their certified EHR, including supporting hardware and interfaces necessary for meeting the program’s requirements without reimbursement from an eligible hospital, and use that certified EHR in the inpatient or emergency department of a hospital, rather than the hospital’s certified EHR. Thus, if you are an eligible professional whose status as a non-hospital based physician changes every year based on your exact patient mix, you may want to consider applying for non-hospital based status in the event that you meet the other requirements as described above.

Additional information on this application process will be made available on the CMS website.

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