What You Need to Know about the MEIP 12 Month Rolling Qualification Period

Reid Haase, REACH HIT Consultant

As many eligible providers (EPs), eligible hospitals (EHs), and critical access hospitals (CAHs) move into year two of the MN Electronic Health Record (EHR) Incentive Program (MEIP), participants are required to qualify for the program annually, in part, by calculating their minimum patient volume (MPV). The MPV has, to this point, been calculated during a chosen 3-month period within the prior calendar year for EPs or the prior fiscal year for EHs and CAHs. For EPs, the threshold for MEIP qualification is 30% of all encounters (20% for pediatric providers) and 10% for EHs & CAHs. With the release of the Stage 2 rule last August, states were given the latitude to also allow a 12-month 'rolling' period as an option along with the 12 month prior calendar or fiscal year. MN opted for, and was granted, the ability to do the new 12-month 'rolling' period as of January 2013. Note that this change can also be utilized by clinics doing a group EP, rather than individual EP qualification.

Program participants can choose either the 12 month prior calendar or fiscal year or opt for the 12-month 'rolling' period which ends the month prior to the month in which they attest. Example: An EP wishes to attest to his/her second year in October 2013. The chosen MPV 30% period could occur in calendar year 2012 or between October 1st, 2012 and September 31, 2013.  An advantage of this rolling 12-month period could be for EPs that recently joined a practice and would otherwise not have the minimum encounter volume. An EH/CAH example of why this would be beneficial would be for those organizations that might not meet the 10% threshold in the prior fiscal year, but were able to meet or exceed 10% when looking at a rolling 12-month period with more recent encounter data.

MPV references (see the first and second bullets on page 67)

Provider Eligibility: Patient Volume Calculation
90-day period for Medicaid patient volume calculation:

• Under Stage 1 rule, Medicaid patient volume for providers calculated across 90-day period in last calendar year (for EPs) or Federal fiscal year (for hospitals)
• Under Stage 2 rule (applicable to all stages), States also have option to allow providers to calculate Medicaid patient volume across 90-day period in last 12 months preceding provider’s attestation
• Also applies to needy individual patient volume