FAQs
FAQs
  • If I am an eligible hospital that qualifies for both Medicare and Medicaid EHR Incentive Payment Programs, and if I have a patient population that is dually eligible, Medicare and Medicaid, can they be counted twice in the calculations?

    For purposes of calculating the Medicaid share, a patient cannot be counted in the numerator if they would count for purposes of calculating the Medicare share. Thus, in this respect the inpatient bed day of a dually eligible patient could not be counted in the Medicaid share numerator. (See 1903(t)(5)(C), stating that the numerator of the Medicaid share does not include individuals “described in section 1886(n)(2)(D)(i).”) In other respects; however, the patient would count twice. For example, in both cases, the individual would count in the total discharges of the hospital.

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  • Is there latitude in defining the 12-month period from which an eligible hospital derives the Medicaid share data?

    The regulation is clear that the discharge-related amount must be calculated using a 12-month period that ends in the Federal fiscal year before the hospital’s fiscal year that serves as the first payment year. 42 CFR 495.310(g)(1)((i)(B). This statement also was made in the preamble, where CMS stated: “For purposes of administrative simplicity and timeliness, we require that States use data on the hospital discharges from the hospital fiscal year that ends during the Federal fiscal year prior to the fiscal year that serves as the first payment year” 75 FR p. 44498. In addition, the regulation indicates that the period that is used for the Medicaid share is the same period as that used for the discharge-related amount. See 42 CFR 495.310(g)(2)(i) referring to “the 12-month period selected by the State.” Use of “the” in 495.310(g)(2) indicates that this is the same 12-month period that is used under 495.310(g)(1).

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