Massachusetts eHealth eQuality Incentive Program RFP
(Solicitation No. 2015-MeHI-01)
Questions and Answers
UPDATED November 24, 2014
QUESTION
1.
Is an applicant required to have 2015 certified
technology?
2.
How do we learn of the highway uses?
3.
Is there any repercussion for not achieving all 4
milestones?
4.
There are situations where we complete
assessment on various state agency websites this could be a duplicate data entry situation. Will
state agencies (EOHHS) take part in the highway?
ANSWER
2011 edition EHR certification, 2014 edition EHR
certification or voluntary edition EHR certification
are all acceptable.
You may read more about certified EHRs here:
http://www.healthit.gov/policy-researchersimplementers/standards-and-certificationregulations
There are many educational resources, including
on the MeHI website:
(http://mehi.masstech.org/health-informationexchange-0/mass-hiway/develop-hiway-use-case)
MeHI plans to have a series of instructional
sessions for grantees. We welcome your use of
the MeHI Use Case Library:
http://mehi.masstech.org/use-case-library.
While new and evolving, this will provide examples
of uses of the HIway. Additionally, you can read
the HIE stories we published over the last few
months (http://mehi.masstech.org/hie-casestudies)
If the organization does not meet a minimum of
Milestone 2 and the Mass HIway Milestone within
2 years of receiving an award, the organization will
be required to repay 50% of any incentive
payments received. [See Solicitation, Section
2.3.3.]
The Mass HIway is under the direction and control
of the Executive Office of Health and Human
Services (EOHHS); as such they are working hard
to connect various public health registries to the
HIway. Learn more here http://www.masshiway.net/HPP/Services/PublicHe
althReporting/index.htm
Additionally, several public registries hosted by
EOHHS are already on the HIway. See the
Massachusetts HIT Council meeting minutes for
more information:
http://www.mass.gov/eohhs/gov/commissions-and-
5.
6.
7.
8.
9.
Can you apply for partial grant? Let's say just to
achieve Milestone 3, but not 4?
If an organization has <30% of providers who are
EP's in the MU program, are those same EP's also
eligible for incentives, or is it ONLY the
professionals who are not a part of the MU
program?
So, the incentives for a small organization are
$33K for the organization and NOT by EP?
What if a BH org that currently has contracts with
EOHHS (DMH, DDS, DPH) decides not to
participate in the information highway, will they be
penalized when re-contracting?
What is the state fiscal year? Oct - Oct?
10. Is this a one-time only RFP? Will it be issued
again in the future?
11. For organizations that are at Stage 0, is there
someone who could provide TA in helping to
understand some of the language put forth in this
RFP?
12. In regards to eligibility criteria number 6, which
specifies more than 50% of the organization’s
patient service revenue must be public payer,
could you please clarify if these payers must be
Medicare, Medicaid and CHIP?
For example, would behavioral health contracts
with DYS, DOC, etc. be applicable?
13. Should we use data from a specific fiscal year to
calculate the percentage of patient service
revenue?
14. May we receive a copy of the webinar presentation
from today?
15. May the electronic version be submitted on a CD
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initiatives/masshiway/hit-council-meetings.html
MeHI requires Applicants to demonstrate
commitment to meeting all 4 milestones. (See the
answer to Question 4 above)
There are limited exceptions for Applicants who
are not eligible for a particular milestone payment.
[See Solicitation, section 2.3.3.]
This incentive program is for eligible organizations
(not individual eligible providers, as under
Meaningful Use). eQIP payments are made to
organizational Applicants.
Correct.
This question is beyond the scope of this
Solicitation and should be directed to EOHHS.
The state fiscal year runs from July 1 – June 30.
However, MeHI will consider flexibility for an
organization to submit data based on its own FY,
so long as the information provided is current and
provides Eligibility Criteria substantiation.
We anticipate this to be a one-time solicitation.
MeHI encourages all prospective applicants to ask
as many questions as they wish if they are unclear
about any terms or language in the RFP.
Questions should be submitted by email to
proposals@masstech.org with the subject line:
Question – Solicitation No. RFP 2015–MeHI–01
MeHI also plans to have a series of instructional
sessions for grantees.
Any public payer revenue may be included,
including Medicare, Medicaid and CHIP.
Revenue under any state or local contract to
provide BH services to public payer clients may be
used.
Data should be submitted for the most recent fiscal
year.
Yes. A copy of the webinar presentation has been
posted to both the MassTech/MeHI and CommBUYS websites.
Yes – either email, CD or USB flash drives with
included in the hard copy submission?
16. What is the telephone number to be used for
FedEx delivery?
17. Where I can download a copy of the eQIP Webinar
presentation?
the hardcopy is acceptable.
The number for FedEx delivery is 508-870-0312
The webinar will be is available on the
MassTech/MeHI and CommBUYS websites.
ADDED ON NOVEMBER 21, 2014:
18. We already operate using EHR, I assume that
make us ineligible for the program?
19. If the current EHR doesn't provide a Client Portal,
can you still apply for the grant to develop a Client
Portal?
20. Do clients have to be all MA residents?
21. What type of documentation would serve to
demonstrate that we are not an Eligible Hospital?
22. In addition to state BH contracts, do contracts with
City and Towns qualify as part of the 50% PSR?
23. Are we an eligible grantee if we are a $20 million
dollar multi service agency, in which BH (both MH
and SA) outpatient and community based services
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Using an EHR does not preclude eligibility.
The Incentive Program is to assist eligible BH
provider organizations to adopt and effectively use
certified EHRs – including integration with the
Mass HIway. Incentive payments are progressive
for reaching advanced health IT integration. See
Solicitation §2.3.3: MILESTONES
Yes. To attain A-EMRAM Stage 5 (Milestone 3),
however, you must use a personal health record or
online patient portal that patients can log into and
receive test results, request an appointment,
receive follow-up reminders, etc.
No. Please note that more than 50% of annual
patient service revenue must be derived from
behavioral health services provided in
Massachusetts.
Please refer to the link below regarding the
parameters and the criteria to qualify as an Eligible
Hospital published by CMS under the EHR
Incentive Programs (e.g., an acute care hospital,
Critical Access Hospital, cancer hospital or
children's hospital, as defined under CMS Program
regulations): - see
http://www.cms.gov/Regulations-andGuidance/Legislation/EHRIncentivePrograms/Eligi
ble_Hospital_Information.html).
In addition to any relevant supporting
documentation, the applicant should include an
affirmative declaration in the Statement of Need
section of its application that the organization does
not qualify for the Medicaid and Medicare EHR
Incentive Programs.
Yes. Revenue under a state or local (county, city
or town) contract to provide BH services to public
payer clients may be used to calculate the
percentage.
An organization is eligible if it provides primarily
BH services in Massachusetts (>50% of annual
PSR is from those BH services). BH includes both
are offered. We bill 3rd party as well as a DPH
BSAS contract for services rendered and the
majority of our clients serviced are Medicaid or
Medicare. We have not participated in any EHR
incentive program offered by Caid/Care as our
psychiatry staff participated with other agencies. If
our total service revenue is around 20 million
(agency wide) which includes corrections,
residential DCF, prevention programs, etc.) the BH
revenues are approximately 3-4 million. Are we
still eligible to apply? Thank you
24. "Milestone 4 states: "use the Mass HIway to
exercise the organization’s use case (e.g., care
coordination with primary care, public health
reporting) in production with at least one
unaffiliated trading partner" Can you please define
"unaffiliated trading partner" AND, do we need to
identify this partner in the application?"
25. If we have already implemented an EHR do we
still need to create a transformation plan?
26. So the BHS revenue is 50% of the agency's total
budget
27. Would DCF residential programs be considered in
your definition of BH services? No third party
billing is done but these are supported by
contracts
28. Would DDS and DMH contracts count as
behavioral health services?
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mental health and substance abuse services. The
setting of care is not dispositive.
Based on the limited facts set forth in the example
cited in the question, an organization with $20
million in annual PSR with $4M from BH services
does not equal 50% of PSR from BH services and
would not meet the threshold.
“Affiliated” is defined in the solicitation (Section
2.2.1) as follows:
Affiliated organizations are entities under common control or
governance (e.g. subsidiary) or joined together contractually
or through a shared entity (e.g., LLC) to enter into payer
contracts that include financial risk or clinical integration.
Entities deemed to be affiliated for the purposes of this
Solicitation if: (1) their financial statements are part of the
same consolidated financial statements under generally
accepted accounting principles; (2) one controls the other
directly or indirectly within the meaning of federal securities
law; or (3) they are under common control within the meaning
of federal securities law.
The trading partner must be identified by the
organization in its Transformation Plan (to be
completed as part of Milestone 1), not in the
application.
Yes. Milestone 1 requires development of a
Transformation Plan that describes how the
Organization will prepare and transform its
practice to maximize the potential of its
investments in health IT in order to achieve
identified outcomes. All organizations must create
a Transformation Plan and submit an A-EMRAM
score to receive payment for Milestone 1.
Organizations must receive more than 50% of
annual patient service revenue (PSR) from the
provision of BH services in the Commonwealth.
PSR is defined as the total of net patient service
revenue (from 3rd party payers) plus payments
under a Massachusetts state or local contract to
provide BH services to public payer clients
Yes – if the DCF contracts are to provide BH
services to public payer clients.
Yes – if those contracts are to provide BH services
to public payer clients.
29. Does eligibility criteria number 6 include Medicaid
MCO plans?
30. Does my EHR have to be certified?
31. My organization does not have a facility license.
Am I still eligible to participate?
32. A few of the clinicians at my organization could
qualify for MU incentives. Would this preclude the
organization from being eligible for eQIP?
Yes – if the Medicaid MCO contracts are to
provide BH services to public payer clients.
Organizations must receive more than 50% of
annual patient service revenue (PSR) from the
provision of BH services in the Commonwealth.
Yes. 2011 edition EHR certification, 2014 edition
EHR certification or voluntary edition EHR
certification are all acceptable.
If the organization is not required to have a facility
license, it is eligible if its providers have valid
professional licenses required to provide BH
services in MA. See Solicitation §2.3.2 Eligibility
Criteria
See also §2.2.1 Definitions: Providers must
provide direct patient care and either be licensed
clinicians or clinical staff authorized to provide
direct patient care under the supervision of a
licensed BH professional.
An organization may be eligible if the number of
EPs total less than 30% of the organization’s
clinical staff, and the organization is either
independent or “parent” has less than $25M
annual patient services revenue in the prior state
fiscal year. See Solicitation §2.3.2 Eligibility
Criteria
ADDED ON NOVEMBER 24, 2014:
33. Per Eligibility Criteria #5a, are there other
substantiation methods that can be used to show
that the potential applicant cannot leverage the
resources of the system parent?
The only method of substantiation listed here
ONLY says that the "parent" has annual Patient
Services Revenue of less than 25 million.
My organization's PSR is MUCH higher than 25
million but we have no access to the resources of
that parent organization.
We cannot leverage their resources. Is there
another way we can show this?
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Under eQIP, MeHI’s goal is to provide incentives
to those BH provider organizations that are not
eligible to participate in other EHR incentive
programs and lack access to other resources to
procure and implement EHRs.
It is presumed that affiliates of larger systems have
greater access to financial and technical resources
and expertise than independent practices.
Organizations that do not satisfy this criterion may
submit an application for an eQIP grant that must
include a narrative explanation indicating the
reasons why the applicant does not have access
to the resources of a parent that has annual
Patient Services Revenue of $25 million or more.
The narrative must be accompanied by
documentation that provides objective evidence in
support of the applicant’s explanation. MeHI will
consider such applications only after reviewing
34. In review of the Eligibility Criteria for the eQIP
Grant, we noted that the organization must be a
not-for-profit in order to participate.
Is there any leniency in this regulation, if we can
prove that the organization does not profit from its
Patient Service Revenue?
applications of organizations that meet all of the
eligibility criteria. MeHI may make funding
available, at its sole discretion, to organizations
that present compelling evidence that a grant
award would advance eQIP’s objectives.
Under eQIP, MeHI’s goal is to provide incentives
to those BH provider organizations that are not
eligible to participate in other EHR incentive
programs and lack access to other resources to
procure and implement EHRs.
It is presumed that “for-profit” organizations have
resources that not-for-profit organizations do not.
35. Would we include our out of state BH contracts
with public payers towards our patient service
revenue?
For profit organizations may submit an application
for an eQIP grant that must include a narrative
explanation indicating the reasons why the
applicant does not have sufficient resources to
procure and implement EHRs. The narrative must
be accompanied by documentation that provides
objective evidence in support of the applicant’s
explanation. MeHI will consider such applications
only after reviewing applications of organizations
that meet all of the eligibility criteria. MeHI may
make funding available, at its sole discretion, to
organizations that present compelling evidence
that a grant award would advance eQIP’s
objectives.
Yes. An organization is eligible if it provides
primarily BH services in Massachusetts (>50% of
annual PSR is from BH services provided in the
Commonwealth).
The Solicitation defines PSR as the total of net
patient service revenue (from 3rd party payers)
plus payments under a Massachusetts state or
local contract to provide BH services to public
payer clients
36. Is there a listing at any type of organization or on
some government website that lists certified EHRs
specifically for behavioral health organizations?
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Applicants should utilize the aggregate amount of
revenue from all operations (in Massachusetts and
out-of-state) as the denominator in the calculation
to determine net patient service revenue. This will
include out-of-state BH contracts with public
payers.
All certified EHR technology (“CEHRT”) is listed on
the ONC Certified Health IT Product List (“CHPL”)
(http://www.healthit.gov/policy-researchers-
37. How much will it cost my organization to connect
to the HIway as required for Milestone 4?
implementers/certified-health-it-product-list-chpl).
It depends on the size of the organization and
method of connection.
See Tier 3 (large BH) and Tier 4 (small BH) on the
HIway rate card:
http://www.masshiway.net/HPP/HowtoJoin/Rates/i
ndex.htm
Note: To the extent that any written answers contained within this Questions & Answers
document are inconsistent with verbal responses given during a Solicitation Webinar, this
written document shall govern.
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