EHR and practice management for mental / behavioral health

Are EMRs Required for Mental Health?

by Leigh-Ann Renz, 1.8.13

…and are mental / behavioral health care practices required to use electronic records??

While there are plenty of reasons to make the switch from paper records to an EMR, some practices are perfectly happy with their current procedures and will only switch to electronic records if it becomes mandatory.  We are frequently asked “Are EMRs required for mental health?  Will I be penalized for not using an EMR?”

Medicare EPs who are not meaningful users of certified technology will be subject to a payment adjustment

We went right to the source, the Centers for Medicare and Medicaid (CMS) and asked them this very question.  The answer depends on whether or not you’re a Medicare eligible professional – here is the verbatim response from CMS: “Medicare eligible professionals who are not meaningful users of Certified EHR Technology will be subject to a payment adjustment beginning January 1, 2015. 

The payment adjustment will be applied to the Medicare physician fee schedule amount for covered professional services furnished by the eligible professional during the year (including the fee schedule amount for purposes of determining a payment based on the fee schedule amount).

The payment adjustment is 1 percent per year and is cumulative for every year that the eligible professional is not a meaningful EHR user. Depending on the total number of Medicare EPs who are meaningful users under the EHR Incentive Programs after 2018, the maximum cumulative payment adjustment can reach as high as 5 percent.”

No Penalty for Medicaid EPs

“For Medicaid Eligible Professionals, there are no payment adjustments under the Medicaid EHR Incentive Program. Therefore, eligible professionals that can only participate in the Medicaid EHR Incentive Program are not subject to payment adjustments.” ~ CMS 

The adjustments will be made to the Medicare Physician Fee Schedule. So, if an office does not bill Medicare, it will not be penalized.

What is the deadline to avoid MU penalties?

To avoid payment adjustments, the timelines vary according to when the Medicare eligible professionals attest to meaningful use. Eligible providers who have demonstrated meaningful use prior to 2014 and continually demonstrate meaningful use every year thereafter will not receive payment adjustments. EPs who first demonstrate meaningful use in 2014 must do so for a 90-day reporting period no later than October 1, 2014 in order to avoid payment adjustments in 2015. This means that you must be using a MU certified system, like PIMSY EHR, by July 1st, 2014, to report on your 90 day consecutive MU on a 2014 Certified EHR no later than October 3, 2014.

The BIG Mental / Behavioral Health Question: am I eligible!?

The most important thing to note, for mental / behavioral health and substance abuse practices is: if you’re not a prescriber, you’re not an eligible professional. See below for details: only MDs, DOs, and NPs qualify in our industry, as they can prescribe medications. If you don’t have a prescriber on staff, your practice does not need to worry about MU.

Tell me more about Meaningful Use, Certification and the ARRA

Eligibility for the Medicare and Medicaid EHR Incentive Programs was defined by law. The American Recovery and Reinvestment Act (Recovery Act) of 2009 provides for incentive payments for Medicare eligible professionals (EPs) who are meaningful users of certified electronic health record (EHR) technology. Section 1848(o) (5) (C) as added by the Recovery Act section 4101 defines the term eligible professional to mean a physician as defined in section 1861(r), which includes the following five types of professionals: doctor of medicine or osteopathy, a doctor of oral surgery or dental medicine, a doctor of podiatric medicine, a doctor of optometry, or a chiropractor. These professionals are eligible for incentive payments for the “meaningful use” of certified EHR technology, if all program requirements are met.

The American Recovery and Reinvestment Act (Recovery Act) of 2009 also provides for incentive payments for Medicaid eligible professionals (EPs) who adopt, implement, upgrade, or meaningfully use certified electronic health record (EHR) technology in their first year of participation in the program and successfully demonstrate meaningful use in subsequent years.  Section 1903(t)(3)(B) of the Recovery Act defines the term eligible professional to mean the following five types of Medicaid professionals: Physicians, dentists, certified nurse-midwives, nurse practitioners, and physician assistants practicing in an Federally Qualified Health Center (FQHC) or a Rural Health Clinic (RHC) led by a physician assistant. Hospital-based EPs are generally not eligible to participate in the EHR incentive program. The only exception is that Medicaid EPs practicing predominately in an FQHC or RHC are not subject to the hospital-based exclusion.

Since Congress enacted the definitions into law, CMS does not have any latitude to include other healthcare professionals.


CMS Medicare & Medicaid EHR Incentive Programs Website
Contact the EHR Information Center at (888) 734-6433
PIMSY Meaningful Use Resource Center
For Mental & Behavioral Health, do you have to use an EHR!?

leigh-Ann Renz is the Marketing & Business Development Director of PIMSY EHR. For more information about electronic solutions for your practice, check out Behavioral Health EHR


Leigh-Ann Renz is the Marketing & Business Development Director of PIMSY EMR. For more information about electronic solutions for your practice, check out Mental Health EHR.


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