- FAQ Topics
- MU Overview
- Eligibility
- Dental
- Performance Measures
- Stage 1, 2013 Performance Measure Changes
- Clinical Quality Measures
- Meaningful Use (EHR) Reporting Period
- Patient Volume - General
- Patient Volume - Eligible Professionals
- Patient Volume - Hospitals
- Patient Volume for 2013 and Beyond
- EHR Certification
- BNP National Site Tracker
- CMS Registration
- Attestation
- Payment Adjustments
Frequently Asked Questions
Last update February 2013Meaningful Use Overview
Q. What is Meaningful Use?
A. Meaningful Use (MU) is using certified electronic health record technology (CEHRT) in a meaningful way with the ultimate objective of improving patient care. The Centers for Medicare and Medicaid Services (CMS) provides incentive payment programs for Eligible Professionals (EPs), Eligible Hospitals (EHs), and Critical Access Hospitals (CAHs) that adopt, implement, upgrade, or demonstrate MU of CEHRT.
MU has three stages:
- Stage 1: 2011 - 2013, collect and share data
- Stage 2: 2014 - 2015, implement advanced clinical processes
- Stage 3: 2016+, improve patient outcomes
Note: Additional requirements to demonstrate MU will be added in each successive stage.
Q. Will state Medicaid programs have different Meaningful Use requirements from the Medicare program?
A. The CMS Final Rule requires that measures reported for Medicare also be applied to Medicaid. However, states have the flexibility to move core objectives to the menu set. Check with your State Medicaid Health Plan (SMHP).
Eligibility
Q. Who is an Eligible Professional (EP) for the Medicaid EHR Incentive Program?
A: EPs under the Medicaid EHR Incentive Program include:
- Physicians (primarily doctors of medicine and doctors of osteopathy)
- Nurse practitioners
- Certified nurse-midwives
- Dentists
- Physician assistants who furnish services in a Federally Qualified Health Center (FQHC) or Rural Health Clinic (RHC) that is led by a physician assistant
Q. Who is an Eligible Professional (EP) for the Medicare EHR Incentive Program?
A. EPs under the Medicare EHR Incentive Program include:
- Doctors of medicine or osteopathy
- Doctors of dental surgery or dental medicine
- Doctors of podiatry
- Doctors of optometry
- Chiropractors
Q. Who is considered a hospital-based Eligible Professional (EP)?
A. An EP is considered hospital-based if 90 percent or more of his or her services are performed in a hospital inpatient (Place of Service code 21) or emergency room (Place of Service code 23) setting. Hospital-based EPs are not eligible for incentive payments.
Q. Are physician assistants (PAs) eligible to participate in the Medicaid EHR Incentive Program?
A. A PA is only eligible to participate in the Medicaid EHR Incentive Program if he or she works at a Federally Qualified Health Clinic (FQHC)/Rural Health Clinic (RHC)/Tribal/Urban clinic and falls into one of these categories:
- When a PA is the primary provider in a clinic (for example, when there is a part-time physician and full-time PA, we would consider the PA as the primary provider);
- When a PA is a clinical or medical director at a clinical site of practice; or
- When a PA is an owner of an RHC.
Q. What does an Eligible Professional (EP) have to do to participate in the Medicaid EHR Incentive Program?
A. For the first participation year, an EP must adopt, implement, or upgrade to a Certified EHR Technology. The EP must also meet the minimum patient volume threshold.
Q. Under the Medicaid EHR Incentive Program, does an eligible professional (EP) need to practice a minimum number of hours per week in order to qualify for an incentive payment? Could a part-time EP qualify for Medicaid incentive payments if the EP meets all other eligibility criteria?
A. Yes, a part-time EP who meets all other eligibility requirements could qualify for payments under the Medicaid EHR Incentive Program. There are no restrictions on employment type (e.g., contractual, permanent, or temporary) in order to be a Medicaid EP.
Q. What is an Eligible Hospital (EH) under the Medicaid EHR Incentive Program?
A. EHs under the Medicaid EHR Incentive Program include:
- Acute-care hospitals (including Critical Access Hospitals [CAHs] and cancer hospitals)
- Children’s hospitals (no Medicaid Patient Volume requirements)
Q. What is an Eligible Hospital (EH) under the Medicare EHR Incentive Program?
A. EHs under the Medicare EHR Incentive Program include:
- "Subsection (d) hospitals" in the 50 states or DC that are paid under the Inpatient Prospective Payment System (IPPS)
- Critical Access Hospitals (CAHs)
- Medicare Advantage (MA-Affiliated) Hospitals
Q. Are IHS hospitals able to participate in both the Medicare and Medicaid EHR Incentive Program?
A. Yes. IHS hospitals are considered dual-eligible and can participate in both programs simultaneously.
Q. Per CMS FAQ # 3017, can tribal clinics be treated as Federally Qualified Health Centers (FQHCs) for the Medicaid EHR Incentive Program?
A. CMS has issued guidance stating that health care facilities owned and operated by American Indian and Alaska Native tribes and tribal organizations ("tribal clinics") with funding authorized by the Indian Self-Determination and Education Assistance Act (Public Law 93-638, as amended), must be reimbursed as FQHCs to be considered FQHCs in the Medicaid EHR Incentive Program. CMS revised this policy and will allow any such tribal clinics, as well as urban clinics that are funded by urban Indian organizations receiving funds under Title V of the Indian Health Care Improvement Act (Public Law 94-437 as amended) for the provision of primary health services (http://www.ihs.gov/ihm/index.cfm?module=dsp_ihm_pc_p3c19#3-19.2D), to be considered as FQHCs for the Medicaid EHR Incentive Program, regardless of their reimbursement arrangements.
Dental
Q. What are the requirements for dentists participating in the Medicaid EHR Incentive Program?
A. Dentists must meet the same eligibility requirements as other eligible professionals (EPs) in order to qualify for payments under the Medicaid EHR Incentive Program. This also means that they must demonstrate all 15 of the core meaningful use (MU) objectives and five from the menu of their choosing. The core set includes reporting on six clinical quality measures (three core and three from the menu of their choosing). Several MU objectives have exclusion criteria that are unique to each objective. EPs will have to evaluate whether they individually meet the exclusion criteria for each applicable objective as there is no blanket exclusion by type of EP.
Q. Is Dentrix, which is the dental EHR, certified?
A. No. There are no certified dental applications at this time. The American Dental Association, which is planning to be the certifying body for electronic dental records, is working on functional requirements and certifying criteria. No projected completion date has been announced at this time.
Q. How can dentists within IHS participate in one of the EHR Incentive programs without the use of a certified dental EHR?
A. Dentists who are working at facilities that are utilizing a 2011 certified version of RPMS EHR can demonstrate Meaningful Use (MU). IHS Electronic Dental Record (EDR) visit data, such as demographics and vitals, is interfaced to the RPMS PCC database. The RPMS MU Performance Measures reports access this data from the PCC database and not the EDR database.
Performance Measures
Q. How many MU Performance Measures must Eligible Professionals (EPs) meet in Stage 1, 2011 - 2012?
A: EPs must:
- Meet 15 core Performance Measures.
- Meet 5 Performance Measures from a menu set of 10. At least one public health measure from the menu set must be met.
- Report on 6 Clinical Quality Measures - 3 core or alternate core measures and 3 measures from the menu set (there are no performance targets).
Q. How many MU Performance Measures must Eligible Hospitals (EHs) meet in Stage 1, 2011 - 2012?
A: EHs must:
- Meet 14 core Performance Measures.
- Meet 5 Performance Measures from a menu set of 10. At least one public health measure from the menu set must be met.
- Report on all 15 Clinical Quality Measures (there are no performance targets).
Q. How many MU Performance Measures must Eligible Professionals (EPs) meet in Stage 1, 2013?
A. EPs must:
- Meet 13 core Performance Measures.
- Meet 5 Performance Measures from a menu set of 10. At least one public health measure from the menu set must be met.
- Report on 6 Clinical Quality Measures - 3 core or alternate core measures and 3 measures from the menu set (there are no performance targets).
Q. How many MU Performance Measures must Eligible Hospitals (EHs) meet in Stage 1, 2013?
A. EHs must:
- Meet 12 core Performance Measures.
- Meet 5 Performance Measures from a menu set of 10. At least one public health measure from the menu set must be met.
- Report on all 15 Clinical Quality Measures (there are no performance targets).
Q. Which Performance Measures are no longer required for Stage 1, CY/FY 2013?
A. Based on the Stage 2 Final Rule, the following Performance Measures have been removed from the core objectives:
- Clinical Quality Measures (CQMs) – no longer separate objectives for reporting; however, Eligible Professionals (EPs), Eligible Hospitals (EHs), and Critical Access Hospitals (CAHs) will still be required to report on CQMs in order to achieve Meaningful Use (MU)
- Electronic exchange of clinical information has been removed
Q. How can Eligible Professionals (EPs), Eligible Hospitals (EHs), and Critical Access Hospitals (CAHs) monitor whether they are meeting Performance Measure targets?
A. To monitor progress, use the Stage 1 Meaningful Use Performance Reports for EPs and EHs/CAHs located on the MUR menu in PCC Management Reports.
Stage 1, 2013 Performance Measure Changes
Q. What are the Stage 1 changes to the menu measure for Eligible Professionals (EPs) for participation year 2013?
A. The following changes are effective for participation year 2013.
- A. Stage 1 Core Measure: Computerized Provider Order Entry (CPOE) - Addition of a new measure
- Current Measure: CPOE is based on the number of unique patients with a medication in their medication list that was entered using CPOE
- New Measure: CPOE is based on the total number of medication orders created during the EHR reporting period
- B. Stage 1 Core Measure: Electronic Prescribing - Addition of an exclusion
- Original Exclusion: Fewer than 100 prescriptions per month
- New Additional Exclusion: EPs can exclude from this measure if the EP does not have a pharmacy within their organization and there are no pharmacies that accept electronic prescriptions within 10 miles of the EP's practice location at the start of his/her EHR reporting period
- C. No Longer Included As a Performance Measure:
- Core Measure: Exchange of Key Clinical Information
- Core Measure: Report Clinical Quality Measures-yes/no answer
Q. How soon may an Eligible Provider (EP) attest to these new measures/exclusions?
A. The earliest an EP may attest to these new measures/exclusions will be April 1, 2013, after satisfying a 90-day reporting period within calendar year 2013.
Q. Are the changes reflected for Stage 1 in 2013 retroactive to CY/FY 2011 or 2012?
A. No.
Clinical Quality Measures
Q. When Eligible Hospitals and Critical Access Hospitals are attesting, how do they determine the numerator, denominator, and exclusion for Clinical Quality Measures (CQMs) ED-1 and ED-2?
A. Detailed instructions are available in MU-CQM-Hospital ED-1 and ED-2 Attestation Instructions [PDF - 230KB].
Q. If the denominators for all three of the core clinical quality measures (CQMs) are zero, do I have to report on the additional CQMs for Eligible Professionals (EPs)?
A. If the denominator value for all three of the core CQMs is zero, an EP must report a zero denominator for all such core measures, and then must also report on all three alternate core CQMs. If the denominator value for all three of the alternate core CQMs is also zero, an EP still needs to report on three additional CQMs. Zero is an acceptable denominator provided that this value was produced by certified EHR technology.
Meaningful Use (EHR) Reporting Period
Q. What is the reporting period for Eligible Hospitals (EHs) and Critical Access Hospitals (CAHs) participating in the Medicare and Medicaid Electronic Health Record (EHR) Incentive Program?
A. For an EH or CAH’s first payment year, the EHR reporting period is a continuous 90-day period within a federal fiscal year. In subsequent years (except 2014), the EHR reporting period for EHs and CAHs is the entire federal fiscal year. In 2014, an EH or CAH can use either the entire federal fiscal year or a three-month period aligned with the quarters of the federal fiscal year.
Q. What is the reporting period for eligible professionals (EPs) participating in the electronic health record (EHR) incentive programs?
A. For demonstrating meaningful use through either the Medicare or the Medicaid EHR Incentive Program, the EHR reporting period for an EP's first year is any continuous 90-day period within the calendar year. In subsequent years (except 2014), the EHR reporting period for EPs is the entire calendar year. Under the Medicaid program, there is also an incentive for the adoption, implementation, or upgrade of certified EHR technology, which does not have a reporting period.
Patient Volume - General
Q. What is the participation year for the Medicaid EHR Incentive Program?
A. The participation year for Eligible Professionals (EPs) is based on the calendar year, and for Eligible Hospitals (EHs), it is based on the federal fiscal year for which payment is applied.
Q. What is the qualification year for the Medicaid EHR Incentive Program?
A. The qualification year for Eligible Professionals (EPs) is the calendar year immediately preceding the participation year. For Eligible Hospitals (EHs) and Critical Access Hospitals (CAHS), the qualification year is the federal fiscal year immediately preceding the participation year.
Q. For participation in CY/FY 2011 – 2012, what timeframe is used to calculate Patient Volume for Eligible Professionals (EPs) and Eligible Hospitals (EHs)?
A. For EPs, encounters are counted during any consecutive 90-day period during the qualification calendar year (January 1 – December 31). For EHs, encounters are counted during any consecutive 90-day period during the qualification fiscal year (October 1 – September 30). The 90 days may not span multiple calendar or fiscal years.
Q. For participation in CY/FY 2013 and beyond, what look-back period is used to calculate Patient Volume for Eligible Professionals (EPs), Eligible Hospitals (EHs), and Critical Access Hospitals (CAHs)?
A. Two options exist.
- Option One: For EPs, encounters are counted during any consecutive 90-day period during the qualification calendar year (January 1 – December 31). For EHs, encounters are counted during any consecutive 90-day period during the qualification fiscal year (October 1 – September 30). The 90 days may not span multiple calendar or fiscal years.
- Option Two: States will have the option to allow EPs, EHs, and CAHs to calculate Medicaid Patient Volume across a 90-day period in the last 12 months preceding the attestation period.
Q. Will a report be provided for RPMS EHR users to help calculate Patient Volume?
A. Eligible Professionals (EPs) and Eligible Hospitals (EHs) that are using the Third-Party Billing Package will be able to run the Patient Volume Reports.
Q. When will the new Patient Volume Report for 2013 calculations be released?
A. The release date is expected in summer 2013.
Q. Will Commercial off the Shelf (COTS) users be able to use the Patient Volume Report created for RPMS EHR users?
A. Although the Patient Volume Report will not be available for COTS users, the logic can be shared upon request.
Q. Per CMS FAQ #3017, my tribal clinic is considered a Federally Qualified Health Center (FQHC) for the Medicaid EHR Incentive Program. So our eligible professionals (EPs) need to have 30 percent "needy individual" patient volume in order to qualify. I understand that needy individual encounters include encounters covered by Medicaid, the Children's Health Insurance Program (CHIP), a sliding fee scale or uncompensated care. My clinic receives Indian Health Services (IHS) funding which only partially offsets the cost of these encounters that are not covered by Medicaid or CHIP, but my clinic does not impose costs on these individuals and does not have a sliding fee scale, so how do I count them?
A. Since your clinic receives IHS funding, the encounters are not truly "uncompensated," but the encounters would be considered services furnished at no cost (even if your clinic does not have a sliding fee scale), and therefore can be counted towards needy individual Patient Volume for tribal clinic-based EPs applying for the Medicaid EHR Incentive Program.
Q. How will 1115 paid encounters be counted in the Patient Volume report for states that have an 1115 waiver in place?
A. RPMS counts 1115 waiver-paid encounters just like Medicaid-paid encounters. Normally, there is not a separate source of payment for 1115 waiver claims; payment is recorded as if the claim were paid by regular Medicaid funds.
Patient Volume - Eligible Professionals
Q. What is the Patient Volume threshold for Eligible Professionals (EPs)?
A. There is a 30 percent Medicaid Patient Volume threshold for EPs, excluding pediatricians.
Q. What is the Patient Volume threshold for pediatricians?
A. Pediatricians may participate in the Medicaid EHR Incentive program if they have a 20 percent Medicaid Patient Volume threshold. Pediatricians with only a 20 percent Patient Volume will receive only two-thirds of the Medicaid Incentive payment. Pediatricians who achieve at least a 30 percent Medicaid Patient Volume will receive the full incentive payment.
Q. When a patient has multiple encounters on the same day with different providers, may all encounters be used for calculating Patient Volume?
A. Yes, multiple providers may include an encounter for the same individual seen by multiple providers on the same day. For example, it may be common for a physician assistant or a nurse practitioner to provide care for a patient, then for a physician also to see that patient. It is acceptable in circumstances like this to include the same encounter for multiple providers when it is within the scope of practice. When a patient has multiple encounters on the same day with different providers, all encounters may be used for calculating Patient Volume, assuming they meet the encounter definitions described above.
Q. When can Eligible Professionals (EPs) utilize the Medicaid Group Patient Volume calculation?
A. The Medicaid Group Patient Volume calculation can be used when all of the providers in the clinic agree to use the group rate for calculating Medicaid Patient Volume. If one does not agree to use the group calculation, then everyone has to use the individual Patient Volume calculation. If the entire clinic reaches the 30 percent paid Medicaid encounter threshold, all EPs in the clinic will have met the threshold. Only the EPs qualify for the incentive payment, even though other providers contributed to the Medicaid encounter volume.
Q. What is considered a Medicaid patient encounter for Eligible Professionals participating in CY 2011 - 2012?
A. Medicaid encounters are non-ER outpatient encounters that are paid in full or in part by Medicaid.
Q. Are Eligible Professionals (EPs) at Federally Qualified Health Centers (FQHCs)/Rural Health Clinics (RHC)/Tribal/Urban clinics able to use the Needy Individual calculation for Patient Volume?
A. For participation in CY 2011 – 2012, the Needy Individual Patient Volume will be used for EPs who work predominately at an FQHC/RHC/Tribal/Urban clinic. An EP is considered to work predominantly at an FQHC/RHC/Tribal/Urban clinic when the FQHC/RHC/Tribal/Urban clinic is the clinical location for more than 50 percent of all of the provider's total encounters for six months in the previous calendar year.
NOTE: Beginning in CY 2013, states will also have the option to allow providers to use a six-month period within the prior calendar year or the preceding 12-month period from the date of attestation for the definition of practicing predominantly.
Q. What is considered a Needy Individual encounter for Eligible Professionals practicing at FQHC/RHC/Tribal/Urban Clinics for participation in CY 2011 - 2012?
A. Needy Individual encounters will include all non-ER outpatient encounters paid in full or in part by Medicaid-insurance type 'D' (includes 1115 Waivers); CHIP-insurance type 'K' billed as either Medicaid or private insurance; discounted (sliding fee scale) encounters; and uncompensated care. The Patient Volume Report in RPMS will include Medicaid and CHIP encounters.
Q. How is Patient Volume for individual Eligible Professionals calculated for participation in CY 2011 - 2012?
A.
Q. How is Needy Individual Patient Volume for Eligible Professionals practicing at FQHC/RHC/Tribal/Urban Clinics calculated for participation in CY 2011 - 2012?
A:
Q. How is the group method calculated for all Eligible Professionals at a clinic for CY 2011 - 2012?
A:
Q. Per CMS FAQ # 3015, when Eligible Professionals/Locum Tenens work at more than one clinical site of practice, are they required to use data from all sites of practice to support their demonstration of meaningful use and the minimum Patient Volume thresholds for the Medicaid EHR Incentive Program?
A. CMS considers these two separate, but related, issues.
Meaningful Use: Any EP demonstrating meaningful use must have at least 50 percent of their patient encounters during the EHR reporting period at a practice/location or practices/locations equipped with certified EHR technology capable of meeting all of the meaningful use objectives. Therefore, States should collect information on meaningful users' practice locations in order to validate this requirement in an audit.
Patient Volume: EPs may choose one (or more) clinical sites of practice in order to calculate their Patient Volume. This calculation does not need to be across all of an EP’s sites of practice. However, at least one of the locations where the EP is adopting or meaningfully using certified EHR technology should be included in the Patient Volume. In other words, if an EP practices in two locations, one with certified EHR technology and one without, the EP should include the Patient Volume at least at the site that includes the certified EHR technology. When making an individual Patient Volume calculation (i.e., not using the group/clinic proxy option), a professional may calculate across all practice sites, or just at the one site.
Q. Are we able to include the Medicaid encounters for our Medicare-eligible professionals in the Medicaid Patient Volume calculation when attesting as a group?
A. Yes. All providers who have a Medicaid encounter within a group practice can be included in the Medicaid Group Patient Volume calculation.
Patient Volume - Hospitals
Q. What is the Patient Volume threshold for Eligible Hospitals (EHs)?
A: There is a 10 percent Medicaid Patient Volume threshold for EHs.
Q. How is Patient Volume calculated for Eligible Hospitals (EHs)?
A:
Patient Volume for 2013 and Beyond
Q. What is considered a Medicaid patient encounter for Eligible Professionals (EPs) beginning in participation year 2013 and beyond?
A. The definition of a Medicaid encounter has changed. The Stage 2 Final Rule constitutes a Medicaid patient encounter as services rendered on any one day to an individual enrolled in Medicaid, regardless of payment liability, including Title 19 and Title 21 Medicaid expansion encounters and those with zero-pay claims.
NOTE: Encounters for patients in stand-alone CHIP programs cannot be included in Medicaid patient volume calculation.
Q. What are zero-pay claims?
A. As long as the service was provided to an individual enrolled in Medicaid, zero-pay claims may include:
- Claims denied because the Medicaid beneficiary has maxed out the service limit
- Claims denied because the services weren’t covered under the State’s Medicaid program
- Claims paid at $0 because another payer’s payment exceeded the Medicaid payment Claims denied because they were not submitted timely
Q. How is the EP Patient Volume calculated for 2013 and beyond?
A. For Non-Medicaid Expansion States:
A. For Medicaid Expansion States:
Q. How is Needy Individual Patient Volume calculated for 2013 and beyond?
A.
EHR Certification
Q. Is the Resource and Patient Management System (RPMS) EHR-certified?
A. Yes. On April 1, 2011, the Indian Health Service (IHS) became the first federal agency to achieve 2011 certification. In order to have the 2011 certified version of RPMS, sites must install the RPMS EHR (BCER version 1.0) with all applicable patches. The Application Checklist [PDF - 20KB] contains a complete listing of all patches necessary to qualify for the certified version of RPMS.
Q. Since IHS has given free licenses for VanDyke, will free licenses also be given for Symantec?
A. Licenses for Symantec EndPoint Encryption and VanDyke (software for AIX systems) were only purchased for IHS-owned equipment. If you are an IHS facility, both applications and licenses are available for free. If you are a Tribal program, you may have to purchase licenses depending on how your facility has managed its shares; however, IHS has recently purchased additional Symantec EndPoint Encryption Software licenses. Sites should contact the OIT Helpdesk (support@ihs.gov) to request additional information.
BNP National Site Tracker
Q. How do I install the BNP National Site Tracker?
A. The installation is a two-step process.
- IHS, Tribal, and Urban sites can install the BNP National Site Tracker software. The BNP software can be installed by downloading it from the BNP server (the RPMS component that contains the install notes and KIDS files).
- To access site information, the Meaningful Use (MU) package reporting client will be needed. It can be downloaded for Windows 2000/XP/7 or Mac. After installing the client, run it on your computer. Different reports can be run by site, by application and for MU requirements.
Q. How do I get my site to appear in the National Site Tracker?
A. In order for the site to show up on this system, the BNP package must be installed on the RPMS system. The download contains instructions and notes for site managers regarding how to install the software on RPMS.
Q. What if my site is not appearing in the National Site Tracker after installing the BNP?
A. BNP requires a network connection to the OIT BNP server. BNP uses an http web service protocol. Please note that this is not a web site. The RPMS server at the site needs to have an open connection on TCP/IP port 80 outbound to nhin.ihs.gov and seal6.ihs.gov at the firewall level. If the port does not open/is not permitted when the site installs BNP, the site will need to re-run ^BNPENV from the programmer prompt. This will force an automatic update from the site immediately.
Q. What if my site has a last report date of more than 24 hours ago?
A. For sites that have installed BNP on their RPMS system, the "Last Report Date" should appear when the Meaningful Use Site Tracking Software is opened on the workstation. If the date is older than 24 hours, the site has not been set up properly. To remedy this situation, the site manager must queue the BNP package to run EVERY 24 HOURS. This will solve the problem of sites not reporting on a regular basis. Site managers needing assistance can run the BNPOST from the programmer prompt, and it will run automatically for them. Next, the entry must be approved in the task manager.
CMS Registration
Q. Where do Eligible Professionals (EPs) register for the CMS EHR Incentive Program?
A. EPs must register for the CMS EHR Incentive Program at CMS EHR Incentive Program
. During registration, they must designate participation in either the Medicare or Medicaid Incentive Program.
Q. Where do EPs register for the Medicaid EHR Incentive Program?
A. First, EPs must register for the CMS EHR Incentive Program at CMS EHR Incentive Program
. During registration, they must designate participation in the Medicaid Incentive Program. The CMS website will redirect EPs to their participation state’s website to continue registration.
Q. Can an EP switch between the Medicare and Medicaid EHR Incentive Programs?
A. EPs can switch as often as they desire—until they receive their first payment. After receiving their first payment, they can only switch once between programs prior to 2015.
Attestation
Q. What is Attestation?
A: Attestation is a legal statement that Eligible Professionals, Eligible Hospitals, and Critical Access Hospitals have demonstrated Meaningful Use and/or all other requirements of the Medicare/Medicaid EHR Incentive Program.
Q. What is the process to attest to CMS for the Medicare EHR Incentive program?
A. Medicare Eligible Professionals, Eligible Hospitals, and Critical Access Hospitals will have to demonstrate meaningful use through CMS' web-based Registration and Attestation System
.
Q. What is the process to attest to CMS for the Medicaid EHR Incentive program?
A. For the Medicaid EHR Incentive Program, providers will use their state’s Attestation System. See the scheduled launch dates for the Medicaid EHR Incentive Programs
.
Q. Can an Eligible Professional (EP) assign the attestation process to another staff member for Medicare?
A. Yes, for the Medicare EHR Incentive Program, an EP can designate a third party to register and attest
on his or her behalf. There are several steps in the process including setting up an account with the CMS Identity and Access Management System (I&A) for the party doing the attestation.
Q. Can an Eligible Professional assign the attestation process to another staff member for Medicaid?
A. Check with your state to see if this functionality will be offered.
Q. According to CMS FAQ # 5993, to qualify for payment under the Medicaid EHR Incentive Program for having adopted, implemented, or upgraded to (AIU) certified EHR technology, eligible professionals (EPs) working at an Indian Health Service (IHS) clinic may be asked to submit to their state Medicaid agency an official letter containing information about the clinic's electronic health record from IHS (an Operating Division of the United States Department of Health and Human Services). The information in this letter identifies the EHR vendor, the ONC Certified Heath IT Product List (CHPL) number of the EHR, as well as other information regarding the EHR product version and licensure. Does this letter meet states' documentation requirements for AIU?
A. Yes. This official letter is from the United States Department of Health and Human Services, and the IHS clinic generating this letter uses a certified EHR system created for the IHS. The state does not need to collect additional documentation for AIU (pre-payment or post-payment, or in the event of an audit) in instances where one of these letters is provided.
Pay Adjustments
Q. What are the payment adjustments for eligible hospitals (EHs) and critical access hospitals (CAHs) that are not participating in the Medicare EHR Incentive Program?
A. As part of the American Recovery and Reinvestment Act of 2009 (ARRA), Congress mandated payment adjustments to be applied to Medicare EHs and CAHs that are not meaningful users of Certified Electronic Health Record (EHR) Technology under the Medicare EHR Incentive Programs. These payment adjustments will be applied beginning on October 1, 2014, for Medicare EHs. Payment adjustments for CAHs will be applied beginning with the fiscal year 2015 cost reporting period. Medicaid EHs that can only participate in the Medicaid EHR Incentive Program and do not bill Medicare are not subject to these payment adjustments.
EHs and CAHs that can participate in either the Medicare or Medicaid EHR Incentive Programs will be subject to the payment adjustments.
