Oral Health and Meaningful Use

Those who deliver dental care to Medicaid patients and the uninsured, safety-net providers, have lacked clearly defined quality measures for established meaningful use of Electronic Health/Dental Records. Despite this, statistics show that dentists have been receiving Medicaid incentive payments in large numbers.

To encourage dental providers, the National Network for Oral Health Access (NNOHA) has published a helpful step-by-step guide for dentists considering meaningful use EHR/EDR incentive programs. As the guide states:

“Although it is possible none of the core quality measures and alternative core quality measures, and additional quality measures are within a dentist’s scope of practice, dentists can STILL meet attestation for Meaningful Use and receive incentive payments.”

Step one is to first verify you are an eligible provider whose patient load consisted of 30% Medicaid patients for at least 90 days in the previous year.

Step 2 is to register, even if EHR/EDR has not been implemented yet. Register with your state for the Medicaid incentive program, and the Centers for Medicare and Medicaid Services (CMS) for the Medicare program. If your state is one of the remaining few that have not started the Medicaid incentive program, than register just with CMS for the Medicare program.

Since incentive payments are given directly to eligible providers and not institutions, administrative agreements should be discussed and recorded prior to registration. In many cases the payment is returned to the institution that oversaw the technology implementation, therefore, this guide points to some sample contracts for administrators:

“The National Association of Community Health Centers has provided sample language for employment contracts/agreements which helps to ensure no misunderstandings arise between the employer and employee.”

The third step is to confirm that the electronic record system adopted is certified. This information is available at the Certified Health IT Product List.

“The Office of the National Coordinator has confirmed that dentists can use an uncertified product to feed information into a certified EHR product, and that as long as the MU information is being captured by the certified EHR Product, this will count towards achieving meaningful use.”

The fourth step is to meet one of the following criteria 1) purchase a certified EHR/EDR technology 2) implement a certified system already purchased 3) upgrade to a certified system, or 4) demonstrate meaningful use of a system already implemented. Be aware that Medicaid incentive payments are significantly larger in the first year of the program in comparison to subsequent years, as seen in the payment schedules. Thus, providers can see a significant benefit from adoption and implementation before they have to demonstrate meaningful use measures. Dental providers are receiving Medicaid incentive payments, even while confusion still exists over clinical quality measures for meaningful use. A study is currently underway by the National Quality Forum to identify quality measures specifically for oral health.

“While there are virtually no oral health measures for dentists in the clinical measure group for Stage 1, many national organizations including NNHOA, NOF, and NACHC are actively working in conjunction with CMS to make the program more applicable to safety-net dental providers.”

The fifth step is to attest to one of the eligible criteria through your state Medicaid agency, and the sixth and final step is receiving payment.

Lessons Learned:

  • While quality control measures may not seem applicable to dental providers, dentists have been qualifying for and receiving Medicaid incentive payments. Several national organizations are working together to define oral health quality clinical measures for meaningful use.
  • Health care administrators should have contract agreements settled between eligible providers and their employers prior to registration with CMS and state Medicaid programs.
  • Be aware that Medicaid incentives are significantly higher than Medicare incentives, and the largest payment comes in the first year of qualification.

National Network for Oral Health Access. (June 2012). Accessing Meaningful Use EHR Incentives Payments. A Step-by-Step Guide for Dental Providers.

National Quality Forum. (2012). Measuring Performance: Oral Health.

Office of the National Coordinator for Health Information Technology. (2012, June 26). Certified Health IT Product List.

Centers for Medicare and Medicaid Service. (2012, August 27). Medicare and Medicaid EHR Incentive Program Basics.