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Medicare Advantage

CMS is renaming the EHR Incentive Programs to the Promoting Interoperability (PI) Programs to continue the agency’s focus on improving patients’ access to health information and reducing the time and cost required of providers to comply with the programs’ requirements. CMS is also in the process of finalizing updates to the programs through rulemaking. For more information, visit the landing page where CMS will publish updates and additional resources as soon as they are available.

Medicare Advantage (MA) organizations may also qualify to receive EHR incentive payments.

Under the Medicare Advantage EHR Incentive Program, payments are made only to Medicare Advantage organizations that are licensed as HMOs, or in the same manner as HMOs, by a state. These Medicare Advantage organizations may receive incentive payments by way of Medicare Advantage eligible professionals and and Medicare Advantage hospitals (MA-affiliated hospitals).

Who are Medicare Advantage eligible professionals?

Medicare Advantage eligible professionals are physicians that are either:

  • Employed by the Medicare Advantage organization


  • Employed by, or partner of, an entity through a contract with the Medicare Advantage organization, that furnishes at least 80% of that entity's Medicare patient care services to enrollees of the MA organization.

Also, Medicare Advantage eligible professionals must furnish at least 80% of their Medicare-related professional services to enrollees of the MA organization and must furnish, on average, at least 20 hours per week of patient care services.

Medicare Advantage eligible professionals cannot directly receive an incentive payment through the EHR Incentive Programs. EHR incentive payments for Medicare Advantage eligible professionals will be paid to the MA organization.


What is a Medicare Advantage affiliated hospital?

Medicare Advantage affiliated hospitals are hospitals that:

  • Are under a common corporate governance with the Medicare Advantage organization


  • Serve individuals enrolled under Medicare Advantage plans offered by the Medicare Advantage organization, where less than one-third are Medicare individuals covered under Medicare Part A.


For additional information regarding the Medicare Advantage EHR incentive payment, please review section 4101(c) of subtitle D of the HITECH ACT.