S.C. Medicaid EHR Incentive Program 2012 SC Health Information Exchange & Health Information Technology Summit

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1 S.C. Medicaid EHR Incentive Program 2012 SC Health Information Exchange & Health Information Technology Summit Susan Hartnett, SCDHHS Division of HIT March 9,

2 Medicare and Medicaid EHR Incentive Programs The American Recovery and Reinvestment Act of 2009 (ARRA) provides for Medicare and Medicaid incentive payments for Eligible Professionals and Eligible Hospitals as they adopt, implement, or upgrade to certified EHR technology; or demonstrate meaningful use of certified EHR technology. 2

3 Notable Differences between the Medicare & Medicaid Incentive Programs Medicaid Voluntary for States to implement No Medicaid fee schedule reductions CMS will implement Medicare Medicare fee schedule reductions begin after 2014 Payment Year One AIU option (Medicaid only) Must begin with MU in Year 1 Max total incentive for EPs is $63,750 Max total incentive for EPs is $44,000 States can require state-specific info for MU Providers may appeal decisions Program sunsets in 2021; the last year a provider may initiate program is 2016 Five Eligible Professional types, and two general types of hospitals (includes CAHs) MU will be common for Medicare Appeals process yet to be developed Program sunsets in 2016 Only physicians, subsection(d) hospitals, and CAHs 3

4 S.C. Medicaid EHR Incentive Program First Program Year 4

5 First Program Year Attestation tool (S.C. Medicaid State Level Repository) Launch of S.C. Medicaid EHR Incentive Program January 2011 Disbursement of incentives began March 2011 $17,977,506 to 852 Eligible Professionals to date 27 Eligible Hospitals have attested Post-payment audits System changes in preparation for 2012 Attestation tail period for attestations for Payment Year One MU attestations for Payment Year Two 5

6 S.C. Medicaid EHR Incentive Program Overview 6

7 Eligibility Requirements for the S.C. Medicaid EHR Incentive Program Eligible Professional (EP) types: Physician Dentist Nurse Practitioner Certified Nurse Midwife Physician Assistant (PA) practicing in an FQHC/RHC that is led by a PA: The PA is the primary provider in the clinic (e.g., a clinic with a parttime physician and full-time PA); or The PA is a clinical or medical director at a clinical site of practice; or The PA is the owner of an RHC. 7

8 Eligibility Requirements for the S.C. Medicaid EHR Incentive Program An eligible acute care hospital is defined as a health care facility with: An average length of patient stay of 25 days or fewer A CMS Certification Number (CCN) in range of or An Eligible Hospital (EH) that meets the requirements of both the Medicare and Medicaid incentive programs may receive incentives from both programs. 8

9 Eligibility Requirements for the S.C. Medicaid EHR Incentive Program EP cannot be hospital-based Defined as an EP who furnishes 90% or more of services in an inpatient or emergency department setting Based upon services in the previous calendar year No state or federal exclusions Payee has active enrollment in the S.C. Medicaid program Meet applicable patient volume threshold Adopt, implement, or upgrade to certified EHR technology (meaningful use required after Payment Year One) 9

10 Registration for the Program 10

11 Registration CMS Registration and Attestation System Providers who wish to participate in either the Medicare or Medicaid program must first register with CMS. The official website for the CMS incentive programs is: CMS EHR Information Center is open to assist with inquiries: , 6:30 a.m. until 5:30 p.m. (Eastern Time), Monday through Friday, except federal holidays. 11

12 Registration CMS Registration and Attestation System During registration with CMS: Provide basic demographic and Payee information Select the state incentive program in which to participate EP may switch their participation between the Medicaid and Medicare EHR Incentive Program: One time switch after first payment Switch must occur before the 2015 payment year 12

13 Registration Identity & Access Management System In order to register and attest on behalf of an EP or EH: The third party must have a CMS Identity and Access Management System (I&A) web user account. Visit RegistrationandAttestation.asp for more information. 13

14 Registration EH: Important Note If an EH plans to participate in both Medicare and Medicaid incentive programs in the same year, it is important that the EH select "Both Medicare and Medicaid" during the CMS registration process. An EH that registers only for the Medicaid program (or only the Medicare program) will not be able to manually change their registration (i.e., change to "Both Medicare and Medicaid" or from one program to the other) after a payment is initiated.

15 Registration S.C. Medicaid State Level Repository Once a provider successfully registers with CMS: A CMS Registration ID is generated and ed to the provider (used for all Participation Years). CMS transmits registration info to the applicable state within 24 hours. SCDHHS Division of HIT conducts a preliminary eligibility check to validate provider is eligible to participate. If eligible, SCDHHS notifies CMS that the registration is approved, and opens the attestation tool to the provider. ( ) If ineligible, SCDHHS notifies CMS that the provider is found ineligible (with the reason); CMS notifies the provider via . 15

16 Registration S.C. Medicaid State Level Repository Important Note: Once successfully registered with the CMS system, we recommend not returning to your CMS account unless a change is needed. If you return to the CMS account (even just to view without modifying your data), you must re-submit your registration with CMS. 16

17 S.C. Medicaid State Level Repository (SLR) To access the attestation tool (SLR), the EP enters: The EP s NPI CMS Registration ID The address provided during CMS registration is used for communications from the S.C. Medicaid EHR Incentive Program. The provider may designate alternate contacts to receive communications as well. 17

18 S.C. Medicaid State Level Repository 18

19 Completing the Attestation 19

20 CMS/NLR Screen Review basic registration information provided at CMS Registration and Attestation System. Any changes must be made at the CMS site. Review S.C. Medicaid ID information If multiple Medicaid IDs are displayed, the provider must select the Medicaid ID associated with the intended Payee. 20

21 CMS/NLR Screen 21

22 Establish Eligibility 22

23 Eligibility Details Screen EP and EH Provider enters information related to patient volume, and AIU/MU. Encounter data and selected 90-day period EHR Details Adopt, Implement, or Upgrade to CEHRT Meaningful Use, if Payment Year Two 23

24 Eligibility Details Screen Other Attestation Details: EP Group patient volume has been used as proxy? Practices predominantly? If using Panel methodology, individuals claimed in the 12-month period prior to 90-day patient volume period 24

25 Establish Eligibility: EP Patient Volume Decision points for the calculation methodology: A) Medicaid encounters? or, Needy Individual encounters? B) Individual EP s encounters? or, Group/Clinic encounters? C) Encounter methodology? or, Panel methodology? 25

26 Establish Eligibility: A) Medicaid or Needy Patient? Medicaid Patient Volume An EP must have a minimum 30% patient volume attributable to Medicaid patients. Pediatricians with a minimum of 20% patient volume but less than 30% can still qualify and will receive a reduced incentive. For purposes of calculating Medicaid patient volume, a Medicaid encounter includes services rendered on any one day where: (1) Medicaid paid for part or all of the service; or (2) Medicaid paid all or part of the individual's premiums, co-payments, and cost sharing. 26

27 Establish Eligibility: A) Medicaid or Needy Patient? Needy Patient Volume An EP who practices predominantly in an FQHC or RHC may meet a minimum volume threshold of 30% patient volume attributable to needy individuals. Practices predominantly: More than 50% of the EP s encounters over a period of 6 months (in the previous calendar year) occurred at an FQHC or RHC. 27

28 Establish Eligibility: A) Medicaid or Needy Patient? Needy Patient Volume A needy patient encounter includes services rendered to an individual on any one day where: (1) Medicaid or CHIP paid for all or part of the service; (2) Medicaid or CHIP paid all or part of the individual's premiums, co-payments, or cost-sharing; (3) The services were furnished at no cost (do not include bad debt encounters); or (4) The services were paid for at a reduced cost based on a sliding scale determined by the individual's ability to pay. 28

29 Establish Eligibility: B) Individual EP s Encounters, or Clinic/Group Patient Volume as Proxy An EP may calculate patient volume based upon the EP s patient encounters; or Clinics and group practices may calculate the clinic or group practice patient volume and offer it as a proxy to the EPs in their practice to use. Clinic or group, for purposes of the S.C. Medicaid EHR Incentive Program, is defined as a group of healthcare practitioners organized as one legal entity under one Tax Identification Number. 29

30 Establish Eligibility: B)Individual EP s Encounters, or Clinic/Group Patient Volume as Proxy Three conditions for group/clinic proxy: (1)The clinic or practice s patient volume is appropriate as a patient volume calculation for the EP; (2)There is an auditable data source to support the clinic or practice s patient volume determination; and (3)The clinic or practice and EPs decide to use one methodology in each year. (If clinic volume is calculated, an EP cannot use his encounters from that clinic for an individual attestation.) The clinic or practice must use the entire practice s patient volume and not limit it in any way; i.e., all encounters for that TIN. 30

31 Establish Eligibility: C) Encounter, or Panel, Formula? Encounter Formula Total Medicaid* patient encounters in any representative continuous 90-day period in the preceding calendar year Total patient encounters in that same 90-day period *100 * Substitute Needy Individual for Medicaid for Needy Individual encounters. *No CHIP beneficiaries may be included in the total Medicaid patient encounters. 31

32 Establish Eligibility: C) Encounter, or Panel, Formula? Panel Formula (EP Only) Total Medicaid* patients assigned to the EP in any representative continuous 90-day period in the preceding calendar year with at least one encounter in the year preceding the start of the 90-day period + Unduplicated Medicaid* encounters in that same 90- day period *100 Total patients assigned to the EP in the same 90-day with at least one encounter in the year preceding the start of the 90-day period + All unduplicated encounters in that same 90-day period * Substitute Needy Individual for Medicaid for Needy Individual encounters. *No CHIP beneficiaries may be included in the total Medicaid patient encounters. 32

33 33

34 34

35 Eligibility Details Screen Other Attestation Details: EH Information re: Growth Rate Information re: Medicaid Share 35

36 36

37 37

38 38

39 EHR Details 39

40 Certified EHR Technology Certified EHR Technology certified by an ONC- Authorized Testing and Certification Body (ONC- ATCB) and reported to ONC. The ONC Certified Health IT Product List is updated at least weekly and serves as the official listing of certified products. 40

41 41

42 42

43 Certified EHR Technology: CHPL Product Number & CMS EHR Certification ID 43

44 Certified EHR Technology: CHPL Product Number Click on Product to see CHPL number. 44

45 Certified EHR Technology: CHPL Product Number CHPL Product Number is displayed. 45

46 Certified EHR Technology: CMS EHR Certification ID To see CMS Cert ID, Add to Cart 46

47 Certified EHR Technology: CMS EHR Certification ID 47

48 Certified EHR Technology: CMS EHR Certification ID The CMS EHR Certification ID is composed of 15 characters. 48

49 EHR Details Screen - AIU AIU: Attest to a legal or financial commitment to adopt, implement, or upgrade to certified EHR technology. 49

50 Attestation Screen 50

51 51

52 52

53 After You Submit 53

54 Attestation Review Once the provider submits the attestation, the attestation is locked. The SCDHHS Division of Health Information Technology (HIT) will review the application to that the provider meets eligibility requirements. HIT staff use the address associated with the account to contact the provider with any questions about the attestation. 54

55 Communication between CMS and the State HIT makes final eligibility check, and communicates intent to pay to CMS. CMS conducts final check on provider alive status and no sanctions; success = Locked for Payment. HIT initiates payment, and reports payment to CMS. 55

56 After Attestation is Approved Electronic credit adjustments process in the weekly payment cycle of the Medicaid Management Information System. Incentive payments are made within 45 days of final determination that the provider has met the program requirements (Locked for Payment). The provider will be notified of the payment by . 56

57 Payment Payment Year 1: EP: Maximum incentive is $21,250 ($14,167 for Pediatricians with reduced Medicaid volume) EH: 50% of calculated aggregate incentive amount Payment Years 2-6: EP: Maximum incentive is $8,500 per year ($5,667 for Pediatricians with reduced Medicaid volume) EH: Payment Year 2: 40% of aggregate amount Payment Year 3: 10% of aggregate amount 57

58 Payment Reassignment EPs have the option of reassigning their incentive payments to their employer or an entity with which the EP has a contractual arrangement. EPs designate the Payee when registering at the CMS Registration and Attestation System. The Payee must be an enrolled S.C. Medicaid provider. 58

59 Documentation and Audits All support documentation for incentive program requirements, including but not limited to that pertaining to patient volume determination, must be retained by the EP for a minimum of six years from the last year of participation in the incentive program, and made available for audits conducted by the SCDHHS, the U.S. DHHS, or contractors acting on their behalf. The audit process includes both desk reviews and onsite audits. 59

60 Plans for 2012 Continue with Payment Year One attestations Begin receiving attestations of meaningful use First year of MU requires a 90-day MU reporting period in the participation year; other years of MU reporting require the full participation year as the reporting period. 60

61 Plans for 2012 The code for the S.C. Medicaid MU attestation tool will be based largely on code used for the Medicare MU attestation tool. Anticipated Go-Live: April Visit CMS Web site for resources on meaningful use (ex: Meaningful Use Calculator) 61

62 State-specific MU Criteria S.C. Medicaid requires eligible providers to report on the public health measure re: immunization reporting (fulfills requirement to select at least one public health measure) unless The provider meets the measure s exclusion criteria, or The EH is deemed a meaningful user through the Medicare EHR Incentive Program. Option to test directly with SCDHEC: Contact (803)

63 Meaningful Use Stage Two Proposed Rule for Stage Two meaningful use requirements was published in the Federal Register March 7. Proposed 1 year delay for Stage 2; proposed minor revisions to certain Stage 1 criteria; proposed minor revisions to calculations of patient volume for Medicaid EHR Incentive Program Comment period is 60 days. CMS National Provider Call: Monday, March 12, 12:30pm 2:00pm ET (registration required) 63

64 Resources CMS Medicare and Medicaid EHR Incentive Programs official Web site: State Medicaid HIT Plan (SMHP), SLR User Guides, and FAQs: SCDHHS Division of Health Information Technology (HIT): 64

65 65

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