The Most Common Misconception about Meaningful Use Heard at RSNA 2011

The most common misconception was that radiologists employed by the hospital are not eligible for the CMS EHR Incentive Program. Unfortunately, this statement is not true.

CMS states that to qualify for the Medicare EHR Stimulus Program, one must meet two criteria: 1) Be a physician; 2) Not be a “hospital-based” physical. The CMS definition of “hospital-based” “Eligible Professional” is clear and has nothing to do with employment.

CMS defines a “hospital-based” physician based on the Place of Service Code (POS) where the physician performs services for CMS patients. To be “hospital-based” (not eligible) requires that a physician furnishes more than 90% of CMS covered services in either inpatient (POS 21) or in the ER department (POS 23) of a hospital. These patients form part of the Hospital patient base for achieving meaningful use.

Services performed in hospital outpatient settings (POS Code 22) are part of the physician patient base for achieving meaningful use. More from the CMS FAQ at

Basically if more than 10% of a radiologist’s covered services are performed on outpatients, they are eligible for the program. And if at least 30% of a physician’s patient volume are Medcaid patients, that physician is eligible for the Medicaid incentives. Otherwise they are eligible for the Medicare incentives and penalties (see Oct 4 blog, “EHR Medicare Incentive Program Overview for Radiology”)..

That’s the long answer.
 the short version from the another CMS FAQ.