Connecticut Medicaid EHR Incentive Program Checklist for Eligible Professionals AIU Last Revision: 11/23/2015 The Medicaid EHR Incentive Program provides incentive payments to eligible professionals (EPs) that are meaningful users of certified Electronic Health Record (EHR) technology (CEHRT). The use of certified EHR systems is required in order to qualify and receive incentive payments. The Office of the National Coordinator for Health Information Technology (ONC) has issued rules defining certified EHR systems and has identified entities that may certify systems, which are listed here: http://oncchpl.force.com/ehrcert?q=CHP. EPs who would like to receive the incentive must choose to adopt and meaningfully use the certified technology in 3 stages for 6 non-consecutive years. Providers are given the option to skip a year but do not have to do so if they are able to attest to Meaningful Use (MU). Providers choosing to adopt, implement or upgrade (AIU) must have upgraded or purchased an EHR system that meets 2014 certification requirements. All EPs must begin the program no later than Program Year 2016 to be eligible to participate. Providers may begin with AIU and then attest for 2 years at each stage of MU. MU occurs in three stages: Stage 1 (data capture and sharing) Stage 2 (advanced clinical processes) begins in 2014 Stage 3 (improved outcomes) expected to begin in 2017 This optional Medicaid EHR Incentive Program checklist provides detailed steps to attest to adopting, implementing, or upgrading to a certified EHR technology in order to qualify for Medicaid incentive payments. This form is intended to be used by the provider or staff attesting on behalf of the provider. Whenever possible, links for additional information are provided. The chart below illustrates the Medicaid MU path providers must follow from AIU or Stage 1 through Stage 3; depending on the year the eligible provider began participating. Medicaid EP Attests in 2011 2011 AIU 2012 Stage 1 2013 Stage 1 2014 Stage 2 2015 Stage 2 2016 Stage 2 2017 2018 2019 2020 2021 Medicaid EP Medicaid EP Medicaid EP Medicaid EP Attests in 2012 Attests in 2013 Attests in 2014 Attests in 2015 AIU Stage 1 Stage 1 Stage 2 Stage 2 Stage 3 AIU Stage 1 Stage 1 Stage 2 Stage 2 Stage 3 CT Medicaid Eligible Professional Checklist AIU Stage 1 Stage 1 Stage 2 Stage 2 Stage 3 1 AIU Stage 1 Stage 1 Stage 2 Stage 2 Stage 3 Medicaid EP Attests in 2016 AIU Stage 1 Stage 1 Stage 2 Stage 2 Stage 3 05/27/2015 ELIGIBILITY FOR MEDICAID EHR INCENTIVES To qualify for incentive payments, health care professionals must meet certain eligibility criteria: Be one of the permissible eligible professional (EP) types Meet patient volume requirements Adopt/ Implement/ Upgrade (AIU) to a certified EHR Show that you are meaningfully using the EHR system Eligible Professionals: The following providers are potentially eligible to enroll in the EHR Medicaid Incentive Payment Program: Physicians Pediatrician: Any provider who is Board Certified as a Pediatrician or has at least 90% of Medicaid Recipients Under the Age of 18 Nurse Practitioners Certified Nurse Midwives Dentists Physician Assistant (PA) practicing in a Federally Qualified Health Center (FQHC) or a Rural Health Center (RHC) which is led by a PA. * An FQHC or RHC is considered to be PA led in the following instances: o The PA is the primary provider in a clinic (e.g., part time physician and full time PA in the clinic) o The PA is the clinical or medical director at a clinical site of the practice o The PA is the owner of the RHC Additional Eligible Professional Requirements: Must not be hospital-based. A hospital-based EP is defined as an EP who furnishes 90% or more of their covered professional services in either the inpatient or emergency department of a hospital and cannot claim allowed hospital exclusion under CFR495.5. Must be licensed to practice in the State of Connecticut. Must not have any current or pending sanctions with Medicare or State Medicaid programs. Must be a CT Medicaid-enrolled provider. CT Medicaid Eligible Professional Checklist 2 11/23/2015 Qualifying for Patient Volume: To be eligible to receive an incentive payment under the Medicaid EHR Incentive Program, an EP must meet one of the following patient volume criteria during a consecutive 90-day period in the preceding calendar year or the preceding 12 month period from date of attestation: Have 30% of your encounters with Medicaid patients (20% for pediatricians) Practice predominately in an FQHC or RHC with a 30% needy individual patient volume threshold. Needy patient volume is defined as patients who are enrolled in the Medicaid or Children’s Health Insurance Program (CHIP), receive uncompensated care, or receive care on a reduced fee scale. ∗ In Connecticut, Children's Health Insurance Program (CHIP) patients, also known as HUSKY B patients, do not count toward the Medicaid patient volume criteria. ∗ Please note that at least one clinical location used in the calculation of patient volume must have CEHRT during the payment year for which the eligible professional attests to adopting, implementing or upgrading to CEHRT or meaningful use. Included in Patient Volume: Medicaid Patients receiving services under HUSKY A, HUSKY C (previously known as Medicaid Fee for Service) and HUSKY D (previously known as Medicaid for Low Income Adults – MLIA) Programs. Providers have the option to include zero-pay claims in their patient volume calculation. If the provider chooses to include zero-pay claims in the calculation, they should be included in the total encounters number (denominator). CT Medicaid Eligible Professional Checklist 3 11/23/2015 ESTABLISHING PATIENT VOLUME Calculation: The patient volume for Medicaid is calculated by dividing Medicaid encounters for the EP during a consecutive 90-day period in the calendar year prior to the program year or a 12 month period preceding the date of attestation by the total encounters over the same 90 day period. The numerator is the number of Medicaid encounters during the 90-day period selected. An encounter is defined as any services rendered on any one day to an individual enrolled in HUSKY A, HUSKY C or HUSKY D; regardless of payment liability, including zero-pay claims. The denominator is all patient encounters for the same EP over the same 90-day period. For example, if the EP had 100 encounters and 30 were Medicaid encounters, they would have a 30% patient volume. Total Medicaid Encounters in any representative, continuous 90-day period in the preceding calendar year or twelve months prior to the attestation = Patient volume * 100 Total Patient Encounters in the same 90-day period Definition of an Eligible Professional Medicaid Encounter For purposes of calculating EP patient volume, a Medicaid encounter is defined as any services rendered on any day to an individual enrolled in HUSKY A, HUSKY C or HUSKY D program. Definition of a Needy Individual Encounter for FQHC/RHC For purposes of calculating patient volume for an EP practicing predominantly in a FQHC/RHC, a needy individual encounter is defined as services rendered on any one day to an individual where medical services were: Furnished by the provider as uncompensated care (charity care) Furnished at either no cost or reduced cost based on a sliding fee scale determined by the individual’s ability to pay To calculate needy individual patient volume, EPs practicing predominantly in a FQHC/RHC must divide: The total needy individual patient encounters in any representative, continuous 90-day period in the preceding calendar year or twelve months prior to the attestation date; by The total patient encounters in the same 90-day period. CT Medicaid Eligible Professional Checklist 4 11/23/2015 Individual vs. Group Patient Volume: Medicaid patient volume thresholds may be met at the individual level (by provider NPI) or at the group practice level. EPs may attest to patient volume under the individual calculation or the group/clinic calculation in any participation year. EPs may use a clinic or group practice's patient volume as their own under the following conditions: The clinic or group practice's patient volume is appropriate as a patient volume methodology calculation for the EP. There is an auditable data source to support the clinic or group practice’s patient volume determination. All the EPs in the group practice or clinic must use the same methodology for the payment year The clinic or group practice must use the entire practice or clinic’s patient volume and not limit it in any way. If the EP works both inside and outside of the clinic or practice, then the patient volume calculation includes only those encounters associated with the clinic or group practice, and not the EP’s outside encounters. For more information on eligibility, go to CMS EHR Incentive Program Eligibility page at http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Eligibility.html FAQ 2993 https://questions.cms.gov/faq.php?id=5005&faqId=2993 CT Medicaid Eligible Professional Checklist 5 11/23/2015 REGISTER WITH FEDERAL AND ENROLL IN THE STATE OPERATED EHR INCENTIVE PROGRAMS Before registering, EPs will need to decide whether to register under the Medicare or Medicaid Incentive program. EPs who qualify for Medicare and Medicaid programs may only participate in one program in a given year. After 2015, EPs will no longer be able to switch incentive between the Medicaid and Medicare programs. EPs who can receive EHR incentive payments under both programs will maximize their payments by choosing the Medicaid EHR Incentive Program. Incentive payments for EPs are based on individual practitioners. If EPs are part of a practice, each EP may qualify for an incentive payment if each EP successfully demonstrates MU of certified EHR technology. This checklist only covers the Medicaid EHR Incentive Program. Third Party Registration CMS implemented functionality that allows an EP to designate a third party to register and attest on his or her behalf. To do so, users working on behalf of an EP must have an Identity and Access Management System (I&A) Web user account (User ID/Password), and be associated to the EP's NPI. If you are working on behalf of an EP(s) and do not have an I&A Web user account, please visit I&A Security Check at: https://nppes.cms.hhs.gov/NPPES/IASecurityCheck.do Gathering Information for Initial Registration in the CMS Medicare and Medicaid EHR Incentive Program Registration & Attestation system: Prior to registering for the CMS EHR Incentive Program, EPs will need to gather the following information. This will help expedite the registration process. You should also identify one individual from your organization that will be responsible for completing registration and attestation information. National Provider Identifier (NPI) o o To locate your NPI number, go to NPPES NPI Registry page at https://npiregistry.cms.hhs.gov/NPPESRegistry/NPIRegistryHome.do If you do not have an NPI number, to apply go to NPPES home page at https://nppes.cms.hhs.gov/NPPES/Welcome.do National Plan and Provider Enumeration System (NPPES) User and ID and Password. If you do not have an NPPES Web user account, go to NPPES home page at https://nppes.cms.hhs.gov/NPPES/ Payee Tax Identification Number (TIN, for reassignment of individual provider benefits to an organization) Payee National Provider Identifier (NPI) (for reassignment of individual provider benefits to an organization) Note: In order to qualify for the CT Medicaid EHR Incentive payments, the EP and the Payee provider must be enrolled providers with Connecticut Medicaid. The payee Tax ID No. and Payee NPI No. must match what is in the provider’s Medicaid Management Information System (MMIS) account with the State of Connecticut. This combination should be the same NPI/TIN that is used for the Connecticut interChange MMIS for claim payment purposes. If you have questions regarding your Connecticut Medicaid enrollment, please contact the CT EHR Provider Assistance Center toll free at 1-855-313-6638. CT Medicaid Eligible Professional Checklist 6 11/23/2015 How to Register & Apply for Medicaid EHR Incentive Program Now that all the information has been gathered, the next step is to register with CMS. All EPs who are participating in the EHR Incentive Program must register for either the Medicare or Medicaid Incentive programs through CMS. This can be done using CMS’ Step-by-Step Guides on Registration for the EHR Incentive Programs at: http://www.cms.gov/Regulations-andGuidance/Legislation/EHRIncentivePrograms/RegistrationandAttestation.html. You will not be able to start your CT Medicaid EHR application in the CT Medical Assistance Provider Incentive Repository (MAPIR) until you have registered with CMS. Register for CMS Registration & Attestation (R&A) System at https://ehrincentives.cms.gov o This is the first step for the first payment year you participate. o If already registered in a previous program year, go directly to the MAPIR application and do not go back to the CMS R&A Web site unless there is a change in TIN or NPI numbers due to a change in the payee receiving the incentive payment. If the provider is actively enrolled in the CT Medical Assistance Program, in approximately 48 hours post-registration, the CT MAPIR system will generate a Welcome email which will be sent to the contact person designated in CMS’ R&A system. The email states the MAPIR system can be accessed by logging onto: https://www.ctdssmap.com/ctportal/?tabname=EHR%20Incentive%20Program. There is an Eligible Professional User Manual that is available on the EHR Incentive Program Web page to assist you with using MAPIR. o If the provider does not have a secure Web portal ID, they are directed to contact the CT EHR Provider Assistance Center at 1-855-313-6638 or an ID may be requested by sending an email to ctmedicaid-ehr@hpe.com. Please ALWAYS include the Provider’s Name and NPI in your correspondence. Once requested the provider or authorized representative is sent two emails, one with a PIN and another with their AVRS ID. Instructions are sent in the email on how to set up the secure provider account. If the provider is not currently enrolled, contact will be made via email instructing the provider how to enroll in the CT Medical Assistance Program. CT Medicaid Eligible Professional Checklist 7 11/23/2015 ADOPT, IMPLEMENT AND UPGRADE (AIU) AIU Certified EHR The provider must attest (verify) that they are using an EHR product certified by the Office of the National Coordinator (ONC). The following steps will assure you are using a federally certified EHR technology for achieving MU in future years. Adopt/Implement/Upgrade (AIU) to a certified EHR technology (CEHRT). A comprehensive listing of certified EHR products can be found at the ONC Certified Health IT Product List at http://oncchpl.force.com/ehrcert?q=CHPL ∗ Please note: Eligible Providers attesting to AIU in 2014 will need to have EHR technology certified to the 2014 Edition EHR certification criteria that meets a required base amount of functionality and then any other functionality they need to achieve meaningful use. http://www.healthit.gov/sites/default/files/pdf/ONC_FS_EHR_Stage_2_Final_082312.pdf Providers should retain and upload appropriate documentation in their EHR Incentive Payment application (e.g. invoices, license agreements, purchase orders, and contracts) which support their attestation for certified EHR technology covering the appropriate EHR Incentive Program reporting period. Proof of adoption, implementation or upgrade of Certified Electronic Health Record Technology (CEHRT) is required for year one of the EHR Medicaid Incentive Payment Program and every year following. Documents Required for AIU (Must be uploaded into MAPIR with attestation): (Documentation must be less than 10 MB) Documentation supporting AIU of Certified EHR Technology including invoice and/or purchase order, and license agreement and/or contract with two authorized signatures (one from EHR vendor, and one from provider/group practice/clinic) CMS EHR 2014 Certification ID cart page showing CMS EHR Certification ID and certified EHR product(s) used. Within the certification ID, the 3rd-5th position of the ID MUST READ 14E Documentation supporting patient volume calculations. This must be a list of all patient encounters for the 90 day period selected including the following information for each encounter: provider’s name and/or NPI, date of service, patient name, patient DOB, patient’s Medicaid ID for Medicaid encounters, and insurance (Medicaid or other insurance). The number of Medicaid encounters and total encounters on this list must coincide with the EP’s patient volume numerator and denominator entered into MAPIR. (NOTE: Preference is for list to be in an excel format) An EP or EH receiving an incentive payment may be asked to provide additional documentation during a pre or post-payment audit. All documentation supporting the information the EP or EH attests to should be kept for 6 years. MAPIR Guide Review the MAPIR User Guide for EPs at https://www.ctdssmap.com/CTPortal/portals/0/ StaticContent/Publications/ehr%20ep%20user%20manual.pdf , which provides step-by-step instructions for login, completing the attestation and uploading documents. CT Medicaid Eligible Professional Checklist 8 11/23/2015 PLEASE VERIFY THAT YOU HAVE THE BELOW INFORMATION AVAILABLE FOR YOUR AIU ATTESTATION: Information from CMS EHR Incentive Program R&A System Information submitted to the CMS Medicare and Medicaid EHR Incentive Program Registration & Attestation (R&A) system including: Payee NPI Payee TIN Email address CMS EHR Certification ID CMS EHR 2014 Certification ID for attestation. This ID is available when you add your certified EHR product(s) to your cart at http://healthit.gov/chpl. Within the ID, the 3rd-5th position of the ID MUST READ 14E CMS ID # Print and retain your CMS EHR Certification ID to enter into the MAPIR system and upload a copy of the Certification ID cart web page in PDF format. Supporting documentation: AIU and MU Must demonstrate a relationship to the eligible professional submitting the evidence of A/I/U and must demonstrate that the eligible professional has a financial and/or legally binding agreement with the EHR vendor. Please see examples of supporting documents below: Purchase Order/Invoice Contract/License Agreement (with 2 Maintenance agreements Upgrade documentation signatures) Patient Volume Data Select your Patient Volume Reporting Period. The reporting period for calculating patient volume is any continuous 90-day period in the preceding calendar year (CY) or in the 12 months preceding attestation. Start Date: End Date: CT Medicaid Eligible Professional Checklist 9 11/23/2015 Out-of-State Encounters Were out-of-state encounters included in the eligible professional’s patient volume calculation? (Yes or No) If yes, from which states or territories? Patient Volume Attestation The following are considered Medicaid Encounters for eligible professionals: Services rendered to an individual on any one day where the individual was enrolled in a Medicaid program (HUSKY A, HUSKY C or HUSKY D) During the 90-day reporting period, what was the eligible professional’s total number of: Medicaid patient encounters? Total Patient encounters? Eligible professionals will be asked to upload documentation supporting their patient volume calculation. This must be a list of all patient encounters for the 90 day period selected including the following information for each encounter: Provider’s name and/or NPI Date of service Patient name Patient DOB Patient’s Medicaid ID for Medicaid encounters Insurance (Medicaid or other insurance) The number of Medicaid encounters and total encounters on this list must coincide with the EP’s patient volume numerator and denominator entered into MAPIR. (NOTE: Preference is for list to be in an excel format.) CT Medicaid Eligible Professional Checklist 10 11/23/2015