Frequently Asked Questions

Transcription

1 The list of questions is ordered and organized by topic (overview, eligibility, patient volume, registration, certified EHR technology, meaningful use, clinical quality measures, stage 2 meaningful use and the Medical Assistance Provider Incentive Repository [MAPIR] system). Sixteen new FAQs have been added as of March 1, 2013 to reflect changes to the 2013 program year. Program Overview What is the Electronic Health Record (EHR) Incentive Program? The EHR incentive program was established by the Health Information Technology for Economic and Clinical Health (HITECH) Act of the American Recovery & Reinvestment Act of The program aims to transform the nation s health care system and improve the quality, safety and efficiency of patient health care through the use of electronic health records. Effective July 13, 2010, the U.S. Department of Health Services (HHS), the Centers for Medicare & Medicaid Services (CMS) and the Office of National Coordinator for Health Information Technology (ONC) released the final rule providing the parameters and requirements for the Medicaid EHR incentive program under the HITECH Act. Can I apply to receive incentive payments from both Medicare and Medicaid? No, not for the same year. You can receive incentive payments only for one program in a given year. You will have to elect either Medicare or Medicaid as the Program you are applying under. After a payment has been made, the Eligible Professional (EP) may switch programs once before Can I apply for Medicaid Incentive Payments in more than one State? No, an Eligible Professional (EP) can only receive Medicaid Incentive Payments from one state per year. When does the program start? Medicaid EHR Incentive programs are voluntarily offered by individual states, Connecticut s Medicaid EHR Incentive Program was launched with the Centers for Medicare & Medicaid Services (CMS) on July 4, CT Medical Assistance Provider Incentive Repository (MAPIR) system has started processing registrations for incentive payments starting September 1, 2011.

2 What is the difference between the Medicare & Medicaid EHR Incentive programs? Medicare Implemented by the Federal Government Maximum incentive is $44,000 for EPs (10% bonus for EPs in Health Provider Shortage Area (HPSAs)) EPs must successfully demonstrate meaningful use of certified EHR technology to receive incentive payments in Year 1 Medicaid Voluntary for States to implement - Connecticut began in July 2011 to accept registrations for the CT Medicaid EHR Incentive Program Maximum incentive is $63,750 for EPs Providers can qualify for an EHR incentive payment for adopting, implementing upgrading or demonstrating meaningful use of certified EHR technology in the first participation year. Required to demonstrate meaningful use of certified EHR technology in each subsequent year to qualify for further EHR payments. Payment reductions begin in 2015 for providers that do not demonstrate Meaningful Use Meaningful Use definition is common for Medicare Last year a provider may initiate program is 2014; Last year to register is 2016; Payment adjustments begin in 2015 Only physicians (doctors of medicine or osteopathy, doctors of dental surgery or dental medicine, doctors of podiatric medicine, doctors of optometry and chiropractors), subsection (d) hospitals and CAHs Incentive amounts are linked to the participation year and decrease year by year. Once a participant receives an incentive payment, they are locked into a payment year succession. No Medicaid payment reductions. States can adopt certain additional requirements for Meaningful Use Last year a provider may initiate program is 2016; Last year to register is types of EPs: non-hospital based physicians (MDs, Dos), nurse practitioners, certified nurse midwives, dentists, and physician assistants that practice at an Federally Qualified Health Center (FQHC) that is led by a PA Incentives can be paid for nonconsecutive participation (i.e. you can skip participation years) through 2021 for EPs.

3 How much are the incentives for eligible professionals? Eligible professionals can receive up to $63,750 over the 6 years that they choose to participate in program. Pediatricians have special rules and they are allowed to participate with a reduced patient volume threshold (20% instead of 30%). If pediatricians participate and have less than 30% patient volume, they receive an incentive reduced to two-thirds, which is $42,500 over six years. If a pediatrician meets or exceeds the 30% patient volume threshold they are eligible for the full incentive payment amounts. Are Medicaid eligible professionals (EPs) subject to payment adjustments or penalties if they do not adopt electronic health record (EHR) technology or fail to demonstrate meaningful use? There are no payment adjustments or penalties for Medicaid providers who fail to demonstrate meaningful use. The Medicare EHR Incentive program does have payment adjustments/penalties. Do I need to have an EHR system in place when the program starts? You do not need to have your certified EHR in place in order to register for the EHR Incentive programs. Medicaid eligible professionals must have adopted, implemented or upgraded to a certified EHR technology in the first year of participation in the EHR incentive program before you will receive an EHR Incentive payment from your State Medicaid Agency. They can demonstrate meaningful use of certified EHR technology in the first year but are not required to do so. Note: Medicare providers must have successfully demonstrated meaningful use in the first year of participation.. First Payment Year Only- Medicaid Eligible Professionals (EPs) and Hospitals may demonstrate the following: Adopted Acquired, purchased or secured access to an ONC certified EHR system Implemented Commenced Utilization (example: Staff training, data entry of patient demographic information into EHR)

4 Upgraded Expanded the available functionality of certified EHR technology capable of meeting meaningful use requirements at the practice site or upgraded from existing EHR technology to certified EHR technology per the ONC EHR certification criteria Must be ONC certified EHR technology capable of meeting meaningful use No EHR reporting period is required In Payment Years 2 through 6 - Medicaid Eligible Professional (EP) and Hospitals must demonstrate Meaningful Use of a Certified EHR 90 day reporting period for participation year 2 Reporting period full calendar year for the participation beyond year 2 except in year 2014 (see below) For 2014 only, all EPs regardless of their stage of meaningful use are only required to demonstrate meaningful use for a 3-month EHR reporting period. CMS is permitting this one-time 3-month reporting period in 2014 only so that all providers who must upgrade to 2014 Certified EHR Technology will have adequate time to implement their new Certified EHR systems. When will the first year payments be made? What is the process for the second year payment? Payments will be made within 60 days of the time when an application has been completed in Medical Assistance Provider Incentive Repository (MAPIR). To receive the second year s payment, the providers have to attest to the 90 (consecutive) day patient volume period in the previous calendar year and to a 90 (consecutive) day Meaningful Use period in the payment calendar year. For all subsequent payment years, providers will have to meet the patient volume in a 90 (consecutive) day period in the previous calendar year and attest to Meaningful Use for the entire payment calendar year. Can I receive the maximum allowable incentive payments if they total more than the cost of purchasing my EHR system? Yes, the incentives are not based on the cost of purchasing EHR technology. As long as an Eligible Professional (EP) or hospital meets all necessary requirements for qualifying for incentive payments, they may receive the maximum allowed amount regardless of what their EHR technology or implementation costs were. My practice is struggling in the current economy and cannot afford an electronic health records (EHR) system. Are there any grants available to help providers like me? Under the Medicare EHR incentive program, there are no grants or upfront money available for the purchase of EHR technology. These incentives are not intended to cover costs, but rather to incentivize adoption and meaningful use of certified EHR technology. Under the Medicaid EHR incentive program, providers may qualify for incentive payments if they demonstrate adoption, implementation, upgrade or meaningful use in their first year of participation, but this money is not available prior to such adoption, implementation or upgrading.

5 Do providers have to contribute a minimum dollar amount toward their certified EHR technology for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs? There is no general requirement under the Medicare and Medicaid EHR Incentive Programs for providers to contribute a minimum dollar amount toward the certified EHR technology that they use. The incentives are not a reimbursement of costs, and providers are not required to contribute a minimum amount toward the purchase or maintenance of their certified EHR technology in order to participate in the EHR Incentive Programs. What is the maximum incentive an eligible professional (EP) can receive under the Medicaid Electronic Health Record (EHR) Incentive Program? EPs who adopt, implement, upgrade, and meaningfully use EHRs can receive a maximum of $63,750 in incentive payments from Medicaid over a six year period (Note: There are special eligibility and payment rules for pediatricians). EPs must register and apply for the incentive payment program by calendar year 2016 to be eligible to receive the maximum incentive amounts. Will providers be allowed to use a proxy for attestation or will they need to do it themselves? Providers can allow a third person to attest on their behalf. However, the provider maintains full responsibility for the veracity of information submitted on their behalf. Where can I get answers to my privacy and security questions about electronic health records (EHRs)? The Office for Civil Rights (OCR) is responsible for enforcing the Privacy and Security rules related to the HITECH program. More information is available at OCR's website at What does the acronym CFR stand for? CFR stands for Code of Federal Regulations and is typically used to refers to the specific line in the federal regulation. Eligibility Which provider types are eligible to participate in the Medicaid EHR? Medicaid eligible professionals (EPs) for an EHR incentive payment are limited to the following: Physician (primarily doctors of medicine and doctors of osteopathy) Nurse Practitioner Certified Nurse-Midwife Dentist Physician Assistant who furnishes services in a Federally Qualified Health Center (FQHC) or Rural Health Clinic that is led by a physician assistant

6 In addition, a Medicaid Eligible Professional (EP) for each year for which the EP seeks an EHR incentive payment: 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 an allowable hospital-based exclusion under 42 CFR 495.5; Must be licensed in the state of Connecticut; Must not have any current sanctions that have temporarily or permanently barred them from participation in the Medicare or State Medicaid programs. Are hospital-based physicians eligible to receive Medicaid EHR Incentive payments? Maybe. Hospital-based physicians who furnish substantially all, defined as 90% or more, of their covered professional services in either an inpatient (POS 21) or emergency department (POS 23) of a hospital are not eligible for incentive payments under the Medicare and Medicaid EHR Incentive Programs. However, there is a new exclusion effective in program year 2013 under 42 CFR which allows EPs who can demonstrate that the EP funds the acquisition, implementation, and maintenance of Certified EHR Technology, including supporting hardware and any interfaces necessary to meet meaningful use without reimbursement from an eligible hospital or CAH; and uses such Certified EHR Technology in the inpatient or emergency department of a hospital (instead of the hospital s CEHRT) are now eligible for EHR Incentive Payments. If I am not eligible for the Medicaid EHR incentive program, is there another way I might receive incentive payments? Based on CMS-specified eligibility criteria, it is possible that even if you are deemed ineligible for the Medicaid EHR Incentive Program, you might qualify for the Medicare EHR Incentive Program. Check the Medicare eligibility guidelines on the Centers for Medicare & Medicaid Services (CMS) Web site at to see if you qualify. If I'm receiving payments under the e-prescribing Incentive Program, can I participate in the EHR Incentive Program as well? EPs who receive a payment through the Medicaid EHR Incentive Program are eligible also to receive an incentive payment through the E-Prescribing incentive program provided they meet all the requirements of that program (e.g., participate on the Medicare fee schedule). For more information, see the EHR incentive program website at Are behavioral/mental health or long-term care practitioners eligible for payments? It depends. In so far as a provider meets the eligibility criteria of a Medicaid eligible professional, then their clinical location or specialty are not factors, i.e. behavioral health or long-term care, etc. However, if they qualify, they would need to meet all requirements of meaningful use like other eligible professionals. If I'm in Physician Quality and Reporting Initiative (PQRI), can I participate in both the EHR Incentive Program as well? Yes, if you are in the PQRI program, you can participate in the EHR incentive program too.

7 Can an Advanced Practice Registered Nurse (APRN) be considered a pediatrician? APRNs are not considered pediatricians. Only physicians can be classified as pediatricians for the purpose of qualifying with 20% Medicaid patient volume for EHR Incentive Payments. APRNs would need to qualify for the 30% patient volume threshold. How are pediatricians defined for the EHR program? Do subspecialists who practice in a pediatric environment count as pediatricians even if they do not have pediatric board certification for their specialty? Pediatrician means a licensed physician engaged in practice where 90 percent of the practice is comprised of patients age 18 and under, and who: (a) (b) (c) (d) Holds board certification by the American Board of Pediatrics in pediatrics or a pediatric subspecialty; in the opinion of the department has training and or experience comparable to that required for board certification by the American Board of Pediatrics in pediatrics or a pediatric subspecialty; holds board certification by the American Board of Medical Specialties in a recognized specialty and serves a pediatric patient population; or in the opinion of the Department of Social Services provides what is generally accepted to be specialty care to a pediatric patient population. Will the resident physicians be eligible to participate in the Medicaid Electronic Health Record (EHR) Incentive Programs? No, all eligible professionals must meet their state's scope of practice rules to participate. For physicians, this typically includes education, licensure, and board examination or certification. Among the requirements to be licensed in Connecticut, all applicants must have completed two years of postgraduate medical training as a resident physician. What are the requirements for dentists participating in the Medicaid EHR Incentive Program? Dentists must meet the same eligibility requirements as other eligible professionals (EP) 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 objectives and five from the menu of their choosing. The core set includes reporting of six clinical quality measures (three core and three from the menu of their choosing.) Several meaningful use 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.- Could a part-time EP qualify for Medicaid incentive payments if the EP meets all other eligibility criteria? Under the Medicaid EHR Incentive Program, is there a minimum number of hours per week that an eligible professional (EP) must practice in order to qualify for an incentive payment?

8 Yes, a part-time Eligible Professional (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 eligible professional. If an eligible professional (EP) meets the criteria for both the Medicare and Medicaid electronic health record (EHR) incentive programs, can they choose which program to participate in? Yes. EPs who meet the eligibility requirements for both the Medicare and Medicaid incentive programs must elect the program in which they wish to participate when they register. After the initial designation, EPs can only change their program selection once after they have received payment before Generally, EPs will maximize the incentive that they are eligible to receive by applying and meeting the requirements of the program under the Medicaid EHR Incentive Program. For the Medicaid Electronic Health Record (EHR) Incentive Program, if the EHR Reporting Period is calendar year (CY) 2013, then the payment year also refers to 2013 even though an eligible professional (EP) may receive the actual incentive payment in early 2014, correct? The payment year is the year for which the payment is made (see 42 CFR and the definition of First, second, third, fourth, fifth, or sixth payment years. ). So, the questioner is correct that if the EHR reporting period is in CY 2013, the payment year also refers to What safeguards are in place to ensure that Medicaid electronic health record (EHR) incentive payments are used for their intended purpose? Like the Medicare EHR incentive program, neither the statute nor the CMS Stage 1 final rule dictates how a Medicaid provider must use their EHR incentive payment. The incentives are not a reimbursement and are at the providers' discretion, similar to a bonus payment. Is data sharing with neighboring States permitted regarding total Medicaid days for purposes of paying full incentives to hospitals or eligible professionals (EPs) with utilization in multiple states under the Medicaid Electronic Health Record (EHR) Incentive Program? Yes. The CMS Stage 1 final rule clarifies the policy about calculating patient volume for Medicaid providers with clinical practices in more than one State, both in terms of what is Medicaid patient volume and about the cross-border issue. See 75 FR 44503, stating: [W]e recommend that States consider the circumstances of border State providers when developing their policies and attestation methodologies. To afford States maximum flexibility to develop such policies, we will not be prescriptive about whether a State may allow a Medicaid EP to aggregate his/her patients across practice sites, if the State has a way to verify the patient volume attestation when necessary. States will propose their policies and attestation methodologies to CMS for approval in their State Medicaid HIT plans. However, as stated in the Stage 1 final rule, EPs and hospitals are permitted to receive payment from only one State in a payment year ( (e)). To view the Stage 1 final rule, please visit: Patient Volumes

9 What Medicaid patient volumes would qualify me for EHR Incentive payments? To qualify for an incentive payment under the Medicaid EHR Incentive Program, an Eligible Professional (EP) must meet one of the following criteria over any continuous 90-day period in the preceding calendar year or 12 months prior to their attestation: 1. Have a minimum 30% Medicaid patient volume; 2. Have a minimum 20% Medicaid patient volume, and is a pediatrician; 3. Practice predominantly in a Federally Qualified Health Center (FQHC) or Rural Health Center and have a minimum 30% patient volume attributable to needy individuals. Needy Individual means an individual receiving care from any of the following (1) CHIP or Medicaid, (2) Uncompensated Care, (3) No cost or reduced cost services on a sliding scale based on the individual s ability to pay Medicaid patients include individuals receiving services under HUSKY C (formally Medicaid Fee-for- Service (FFS)), HUSKY D (formally Medicaid for Low Income Adults (MLIA)) and the HUSKY A programs. What time frame is used to calculate the patient volume? To calculate patient volume an Eligible Professional (EP) must divide the total Medicaid patient encounters in any representative continuous 90-day period in the preceding calendar year or 12 months prior to their attestation by the total patient encounters in the same 90-day period. An encounter is defined as services rendered to a HUSKY A (Medicaid Fee For Service (FFS)), HUSKY D (formally Medicaid for Low Income Adults (MLIA)) or HUSKY A individual on any one day where Medicaid, HUSKY D or a Medicaid Managed Care Organization paid for part or all of the service; or paid all or part of the individuals premiums, co-payments, and cost-sharing. Can we use volume for the first three quarters of 2011 for the 2011 payment year? To be eligible for the EHR incentive payments in any give year, providers need to meet the patient volume requirements in any 90 consecutive days in the previous calendar year or 12 months prior to their attestation. The period does not necessarily need to fall within a specific quarter; it just needs to be a 90 consecutive day period. When calculating Medicaid patient volume or needy patient volume for the Medicaid EHR Incentive Program, are eligible professionals (EPs) required to use visits, or unique patients? There are multiple definitions of encounter in terms of how it applies to the various requirements for patient volume. Generally stated, a patient encounter is any one day where an individual enrolled in a Medicaid program receives service. The requirements differ for EPs and hospitals. In general, the same concept applies to needy individuals. Is 30% the number of visits or the number of patients? For calculating the Medicaid Patient Volume, an encounter is defined as services rendered to a Medicaid Medicaid Fee For Service (FFS), Medicaid for Low Income Adults (MLIA) or HUSKY A individual on any one day where Medicaid, MLIA or a Medicaid Managed Care Organization paid for part or all of the service; or paid all or part of the individuals premiums, co-payments, and cost-sharing.

10 Are the Managed Medicaid patients included with the straight Medicaid patients for total volume? Only HUSKY A patients should be included in the calculation of Medicaid patient volume. How are the reporting periods for Medicaid patient volume affected if an eligible professional (EP) skips a year or takes longer than 12 months between attestations? Regardless of when the previous incentive payment was made, the following reporting periods apply for the Medicaid EHR Incentive Program and patient volume, an eligible professional (EP) should use any continuous, representative 90-day period in the prior calendar year or 12 months prior to attestation. How does CT Medicaid define clinic or group for the purpose of attesting using clinic or group practice s patient volume as a proxy for the individual eligible professional (EP)? To address this question it is important to consider the various provider approaches to enumerating. Groups and clinics enroll in CT Medicaid using their organization NPI. Some groups/clinics opt to use a different NPI for each separate specialty group or clinic site whereas others use the same organization NPI to enroll their various specialty groups or clinic sites. Each group/clinic enrolled in CT Medicaid is assigned an Automated Voice Response System (AVRS) ID. Claims are processed per AVRS ID and Remittance Advices are generated per AVRS ID. An Eligible Professional using group volume as a proxy for his/her individual patient volume is asked to enter the group/clinic ID whose volume they are submitting. The only ID allowed to be entered in MAPIR is the NPI for the group/clinic. If the provider has only one group/clinic enrolled in CT Medicaid under the organization NPI, this approach presents no problem in the application review process. When more than one clinic/group is enrolled in CT Medicaid under the same organization NPI, the preferred approach is for the EP to attest with the volume for their entire organization and not just for the AVRS ID for their specialty group or clinic site that they work at. The reason for this approach is that the NPI entered as the group/clinic ID belongs to the EP s organization and not just the one AVRS ID. Entering the entire organization s volume simplifies the application review process which aggregates data by NPI. If an EP does not want to use the organization volume as a proxy for their individual volume, they do have the option to attest with the volume for their specific specialty group or clinic site (AVRS ID). In these situations, the application review process will require some follow up documentation from the provider. Using the volume for the specific specialty group or clinic site (AVRS ID) only works if each specialty clinic is truly organized as a separate clinic, with a separate billing number used for all of its claims, and a clearly defined staff. The larger organization would also need to make sure that it consistently reports patient volume only using its specialty clinic patient volumes (with the same methodology throughout the organization, and no double-counting of encounters). For the Medicaid EHR Incentive Program, can a non-hospital based eligible professional (EP) include their in-patient encounters for purposes of calculating Medicaid patient volume

11 even if the patient is included in the eligible hospital's patient volume for the same 90-day period? Yes, an EP who sees patients in an in-patient setting, and is not hospital based, can include the inpatient encounter in their Medicaid patient volume calculation. Both an eligible hospital and an EP can include an encounter from the same patient in their Medicaid patient volume calculations, respectively. This is because the services performed by the EP are distinct from those performed by the eligible hospital. Section defines an encounter as a service rendered to an individual enrolled in a Medicaid program by either an EP or an eligible hospital. An EP who sees patients in an in-patient setting bills Medicaid for the services personally rendered by the EP, while at same time the hospital bills Medicaid for the services rendered by the hospital, such as the bed and medications. Given that these are two distinct sets of services for the same patient, both the eligible hospital and the EP can count them as an encounter for Medicaid patient volume if they happened to select the same 90-day period. The EHR Incentive Programs Stage 2 Rule describes changes to how a state considers CHIP patients in the Medicaid patient volume total when determining provider eligibility. In Connecticut, are patients in CHIP programs now considered appropriate to add in the Medicaid patient volume total? No, patients in standalone CHIP programs established under Title 21 as present in Connecticut are not to be considered part of the patient volume total per the CMS stage 2 rule. So you may not include Husky B patients in your patient volume totals. Can eligible professionals (EPs) round their patient volume percentage when calculating patient volume in the Medicaid Electronic Health Records (EHR) incentive program? To participate in the Medicaid EHR incentive program, EPs are required to demonstrate a patient volume of at least 30% Medicaid patients over a 90-day period in the prior calendar year or in the 12 months before attestation. The Centers for Medicare and Medicaid Services allow rounding 29.5% and higher to 30% for purposes of determining patient volume. Similarly, pediatric patient volume may be rounded from 19.5% and higher to 20%. How can an eligible provider (EP) that is new to a practice meet the patient volume/practice predominantly criteria to be eligible for the Medicaid Electronic Health Records (EHR) Incentive Program? There a three ways an EP could meet the patient volume/practice predominantly criteria to potentially qualify for an incentive payment. For illustrative purposes, assume the EP in the below example joined the practice in 2013:

12 Next year (2014), after the EP establishes his/her own 90-day patient volume period as an EP from the prior calendar year (2013) or 12-month period prior to attestation. This year (2013), if he/she is part of a group using the group patient volume proxy and it is appropriate to include him/her (i.e., he/she see Medicaid patients*). It is not a requirement that he/she was in the group for the period that is the basis for the proxy. However, using the group patient volume proxy is distinct from whether an EP practices predominantly in a Federally Qualified Health Center (FQHC) or Rural Health Center (RHC). To meet the "practice predominantly" criterion, an EP must use individualized data; there is no group proxy (see below bullet). If the EP is working in an FQHC or RHC, next year (2014), after the EP practiced predominately in his/her the FQHC/RHC for at least 6 months. The EP could then use either individual or group proxy needy individual patient volume. FQHCs/RHCs using the group proxy must follow the regulations, including ensuring all EPs in the clinic use the proxy, and counting only encounters associated with the clinic (not an EP's outside encounters). Connecticut has a method to determine whether or not an EP is considered hospital-based. Generally, we use data from the prior fiscal or calendar year to make this determination. *Note that it is within the state s discretion to require validation of an EP s status as a Medicaid provider in the form of a paid encounter from the previous year. If the EP is new to practicing medicine (e.g., a recent graduate of an appropriate training program), he/she is not required to provide such information. Registration When and where do I register? Eligible Professionals (EPs) must first register with the Centers for Medicare & Medicaid Services (CMS) using the EHR Incentive Program Registration and Attestation System (R&A) at After completing that registration and electing the Medicaid program, EPs will receive a welcome and will also need to register in the Connecticut Medical Assistance Provider Incentive Repository (MAPIR). The Eligible Professional (EP) will be able to access MAPIR via the secure provider portal at If an EP does not have a logon ID to the secure provider portal, the provider will need to contact HP by at ctmedicaid-ehr@hp.com or by phone at in order to obtain a logon ID. IMPORTANT NOTE: If a provider is going to register for the Medicaid incentive they must be enrolled in the CT Medical Assistance Program as either a performing or billing provider.

13 What is the next step after Registering with CMS? Once EPs register with the Centers for Medicare & Medicaid Services (CMS) Registration and Attestation system and have chosen to apply for the Connecticut Medicaid incentive program, the EPs will need to register and attest in the Connecticut Medical Assistance Provider Incentive Repository (MAPIR). The providers have to Attest that they have adopted, implemented, upgraded or are meaningfully using Certified EHR technology to qualify for the incentive payment. MAPIR is a web based application that interfaces with the CMS EHR Incentive Program Registration and Attestation System for the exchange of data regarding Eligible Professional (EP) state selection and subsequent provider payments. The EPs can access MAPIR via the secure provider portal at EPs who do not have a logon ID to the secure provider portal should contact HP at Do I have to be enrolled in the CT Medical Assistance Program to apply for the Connecticut Medicaid EHR Incentive? Yes. If you are a performing provider who will be registering for the Medicaid EHR Incentive Program, you will need to obtain access to the secure provider portal on the Web. To obtain access you must be enrolled in the Medicaid Medical Assistance Program. Enrollment in the program maybe completed through the Connecticut Medical Assistance Program Enrollment/Re-enrollment Wizard at under the Provider drop down menu select Provider Enrollment. Enrollment in the program takes about 6-8 weeks. What do I need in order to register (once registration is available)? To register with the CMS Medicare & Medicaid EHR Incentive Program Registration and Attestation System go to For detailed instructions on registering with the Centers for Medicare & Medicaid Services (CMS) Medicare & Medicaid EHR Incentive Program Registration and Attestation System, go to the following site: To participate in the Medicaid EHR Incentive Program all EPs will need the following information when registering with the CMS Medicare & Medicaid EHR Incentive Program Registration and Attestation System: National Plan and Provider Enumeration System (NPPES) User ID and Password National Provider Identifier (NPI) Provider Tax Identification Number Payee Tax Identification Number if you are reassigning your incentive payments Payee National Provider Identifier if you are reassigning your incentive payments

14 Once EPs register with the CMS Registration and Attestation system and have chosen to apply for the Connecticut Medicaid incentive program, the EPs will need to register and attest in the Connecticut Medical Assistance Provider Incentive Repository (MAPIR). Do I need to have an EHR system in place when the program starts? You do not need to have your certified EHR in place in order to register for the EHR Incentive programs. However, Medicaid eligible professionals must have adopted, implemented or upgraded (A/I/U) a certified EHR technology in the first year of participation in the EHR incentive program before you can receive an EHR Incentive payment from the Connecticut Department of Social Services. They can demonstrate meaningful use of certified EHR technology in the first year but are not required to do so. Note: Medicare providers must have successfully demonstrated meaningful use in the first year of participation. Do providers register only once for the Medicaid Electronic Health Record (EHR) Incentive Programs, or must they register every year? Providers are only required to register once for the Medicaid EHR Incentive Program using the Centers for Medicare & Medicaid Services (CMS) EHR Incentive Program Registration & Attestation System, a web-based system. However, they must successfully demonstrate that they have adopted, implemented or upgraded (first participation year for Medicaid) or meaningfully used certified EHR technology each year in order to receive an incentive payment for that year. If any basic registration information changes, the provider will need to update their information in the Medicare and Medicaid EHR Incentive Program Registration & Attestation System Additionally, providers seeking the Medicaid incentive must annually re-attest to other program requirements, such as meeting the required patient volume thresholds. Providers who select the Medicaid EHR Incentive Program will demonstrate their eligibility and attest via their Connecticut Medical Assistance Provider Incentive Repository (MAPIR) system. Can providers participating in the Medicaid EHR Incentive Program update their information (for example, if an address was mistakenly entered?) If so, will CT MAPIR receive an update or refresh of this information for its Medicaid EHR Incentive program? Yes, providers who have registered for the Medicaid EHR Inventive Programs may correct errors or update information through the registration module on the Centers for Medicare & Medicaid Services (CMS) Registration & Attestation website ( The updated registration will be shared with us. Certified EHR Technology

15 What is the purpose of certified electronic health record (EHR) technology? Certification of EHR technology provides assurance to purchasers and other users that an EHR system or product offers the necessary technological capability, functionality, and security to help them satisfy the meaningful use objectives for the Medicare and Medicaid EHR Incentive Programs. Confidence in health IT systems is an important part of advancing health IT system adoption and realizing the benefits of improved patient care. What does A/I/U stand for? A/I/U is an acronym for Adopt / Implement / Upgrade a certified EHR technology. During the first payment year of the Medicaid EHR Incentive program, eligible professionals who qualify under this program may demonstrate that either they have (1) Adopted, (2) Implemented or (3) Upgraded a certified EHR System. Adopted: A provider has acquired and installed certified EHR technology, for example, can show evidence of purchase and installation Implemented: A provider has begun using certified EHR technology, for example, provided staff training or data entry of patient demographic information into EHR Upgraded: A provider has expanded existing technology to meet certification requirements, for example, upgraded to certified EHR technology or added new functionality to meet the definition of certified EHR technology The EHR must be ONC certified EHR technology capable of meeting meaningful use. EPs that elect to perform A/I/U in year 1 of the Medicaid EHR incentive program do not have to meet the meaningful use reporting requirements during that Medicaid EHR Incentive Program year. Where can I find a list of certified Electronic Health Record (EHR) technology? A list of certified EHR technology is available through the Office of the National Coordinator for Health Information Technology (ONC) at What information will I need to provide about my EHR system? Once you adopt, implement, or upgrade a certified EHR system, you will need the following information for both A/I/U and meaningful use attestation: CMS EHR Certification Identification (ID) You should also retain all documentation supporting your adopting, implementing and using a certified EHR system including copies of invoices, license agreements, purchase orders, and contracts which support attestation for certified EHR technology and show the names of the vendor(s), product(s) and version numbers.

16 What is a CMS EHR Certification ID? To qualify for the incentive payments, the EHR technology needs to be certified to meet certain standards and the meaningful use criteria. Eligible professionals (EPs) are required to obtain a CMS EHR Certification ID at: The CMS EHR Certification Number is required for attestation for the Medicaid Incentive Program. The CMS EHR Certification ID is not the same as the CHPL Product Number and is instead obtained by adding certified EHR technology product(s) to the cart the above website and requesting the CMS EHR Certification ID when the products meet 100% of the criteria for stage 1 meaningful use. What is the Certified HIT Product List? The Certified HIT Product List (CHPL) found at provides the authoritative, comprehensive listing of Complete EHRs and EHR Modules that have been tested and certified under the Temporary Certification Program maintained by the Office of the National Coordinator for Health IT (ONC). Each Complete EHR and EHR Module on the CHPL website has been certified by an ONC- Authorized Testing and Certification Body (ONC-ATCB) and reported to ONC. Only the product versions that are included on the CHPL are certified under the ONC Temporary Certification Program. Is the CHPL Product Number the same as the CMS EHR Certification ID? No, the Office of the National Coordinator (ONC) CHPL Product Number is different from the CMS EHR Certification ID. To obtain the CMS Certification Number add complete or modular EHR products to your cart on the Certified Health IT Product List website until the combination of these products reach 100% of the meaningful use requirements. Then click the button to generate the unique CMS EHR Certification ID for that combination of products. What is a complete EHR? What is an EHR module? The ONC through its testing bodies classifies EHR products as Complete EHRs and Modular EHRs on its Certified Health IT Product List website at Complete EHR have been certified to meet all the mandatory certification criteria as identified in the Standards and Certification Criteria Final Rule (45 CFR Part 170 Part III). Complete EHR products listed on the CHPL website have been certified to meet all of the General Criteria listed in Section , plus all of the criteria applicable to a type of practice setting. (In the Final Rule, the certification criterion for Accounting for Disclosures ( (w)) is optional for systems or technologies seeking certification and may not appear.) EHR Modules are those technologies that are certified to at least one of the certification criteria as defined in the Standards and Certification Criteria Final Rule. Due to the regulatory requirement that EHR Module technologies be certified to the security criteria elaborated in the Final Rule, many EHR Modules will be certified to more than one of the regulatory criteria. If a provider chooses a EHR Module, multiple EHRs products would need to be used to meet 100% of the meaningful use criteria while if a complete EHR is choose, only one EHR system would be required. For both modular and complete EHRs

17 additional software components may be required to be purchased to meet all the criteria as certified by ONC s certification and testing bodies. Refer to the additional software required for a particular EHR listing. Meaningful Use What is meaningful use? I keep hearing about it, but I don't understand what it means. Under the Health Information Technology for Economic and Clinical Health (HITECH Act), which was enacted under the American Recovery and Reinvestment Act of 2009 (Recovery Act), incentive payments are available to eligible professionals (EPs), critical access hospitals, and eligible hospitals that successfully demonstrate meaningful use of certified EHR technology. The Recovery Act specifies three main components of meaningful use: 1. The use of a certified EHR in a meaningful manner, such as e-prescribing. 2. The use of certified EHR technology for electronic exchange of health information to improve quality of health care. 3. The use of certified EHR technology to submit clinical quality and other measures. Eligible professionals are not required to meet meaningful use for each consecutive year after they have received their first incentive payment for adoption, implementation, and upgrade of certified EHR technology. However, incentive payments will only be made for the years that an eligible professional has demonstrated successful meaningful use of certified EHR technology. Stage 1 Meaningful Use Criteria 13 Core Objectives (examples: CPOE, e-prescribing, record demographics, clinical quality measures, etc.) 5 Objectives out of 10 from menu set (examples: drug-formulary checks, incorporate clinical lab test results as structured data, generate lists of patients by specific conditions, etc.) 6 total Clinical Quality Measures Providers seeking additional information should click the following link: Where can I find the list of 13 Stage 1 meaningful use objectives? The Meaningful Use Objectives specification sheets for the Medicare and Medicaid EHR Incentive Programs bring together critical information on each objective to help eligible professionals understand what they need to do to demonstrate meaningful use successfully. For eligible professionals, there are a total of 23 meaningful use objectives. To qualify for an incentive payment, 18 of these 23 objectives must be met, including: 13 required core objectives 5 menu set objectives that may be chosen from a list of 10

18 The meaningful use objectives specification sheets for EPs can be found at TOC.pdf. Can we implement an EHR system and satisfy meaningful use requirements at any time within a January 1-Dec. 31 calendar year? For Medicaid providers' first participation year, they do not have to demonstrate meaningful use (if they do, it is the same requirement of 90 consecutive days for the EHR reporting period as for Medicare providers). They only have to demonstrate that they have adopted, implemented or upgraded certified EHR technology and there is no reporting period for this requirement. It simply has to have been accomplished before they attest to that fact to the State. The first year a Medicaid provider demonstrates meaningful use the EHR reporting period is 90 days. Under the Medicaid Electronic Health Record (EHR) Incentive Program, if a provider adopts, implements or upgrades (AIU) certified EHR technology in their first year, the provider will not have to demonstrate meaningful use in order to receive payment; in the second year they will have to demonstrate MU for a 90 day period only. Whereas a provider that is already a meaningful user would have to demonstrate for a 90 day period the first year and subsequent years they would have to demonstrate it for the full year. Is this correct? This is correct. However, 24 CFR establishes a one-time exception for providers attesting to meaningful use in 2014 during which the reporting period for Medicaid providers is any continuous 90-day period within the reporting year. For the Medicare and Medicaid EHR Incentive Programs, what changes were made to Stage 1 objectives and policies in the August 23, 2012 Final Rule? The August 23, 2012, final rule includes some changes to the Stage 1 meaningful use objectives, measures, and exclusions for eligible professionals, eligible hospitals, and critical access hospitals. Some of these changes will take effect as early as October 1, 2012, for eligible hospitals and critical access hospitals, or January 1, 2013, for eligible professionals. Other Stage 1 changes will not take effect until the 2014 fiscal or calendar year, and will be optional in 2013.Please see the full FAQ online to see a chart of the changes to specific objectives, measures and policies: The Recovery Act requires the electronic exchange of health information. Is there funding to pay for connectivity between clinical practices and hospitals? Will there be federal guidance, or will this be hashed out at a local/community level?

19 The Office of the National Coordinator has established 56 Health Information Exchange Cooperative Programs to assist States and territories' efforts to rapidly build capacity for exchanging health information across the health care system both within and across stales. These exchanges will play a critical role in facilitating the exchange capacity of clinicians, laboratories, pharmacies and hospitals, etc in their jurisdictions to help them in meeting the health information exchange requirements which are part of meaningful use. More information on ONC's Health Information Exchange grantees can be found at: home/1204 Do specialty providers have to meet all of the meaningful use objectives for the Medicaid EHR Incentive Programs, or can they ignore the objectives that are not relevant to their scope of practice? For eligible professionals (EPs) who participate in the Medicaid EHR Incentive Program, there are a total of 23 stage 1 meaningful use objectives. To qualify for an incentive payment, 18 of these 23 objectives must be met. There are 13 required core objectives. The remaining 5 objectives may be chosen from the list of 10 menu set objectives. Certain objectives do provide exclusions. If an Eligible Professional (EP) meets the criteria for that exclusion, then the EP can claim that exclusion during attestation. However, if an exclusion is not provided, or if the EP does not meet the criteria for an existing exclusion, then the EP must meet the measure of the objective in order to successfully demonstrate meaningful use and receive an EHR incentive payment. Failure to meet the measure of an objective or to qualify for an exclusion for the objective will prevent an EP from successfully demonstrating meaningful use and receiving an incentive payment. What is the reporting period for eligible professionals (EPs) participating in the electronic health record (EHR) incentive programs? For demonstrating meaningful use through the Medicaid EHR Incentive Program, the EHR reporting period for an Eligible Professional s (EP) first year of meaningful use reporting (second year of payment if reported A/I/U in year 1) is any continuous 90-day period within the calendar year. In subsequent years, the EHR reporting period for EPs is the entire calendar year. There is also an incentive for the adoption, implementation, or upgrade of certified EHR technology in year 1, which does not have a reporting period. Is the physician the only person who can enter information in the electronic health record (EHR) in order to qualify for the Medicare and Medicaid EHR Incentive Programs? No. The Final Rule for the Medicare and Medicaid EHR incentive programs, specifies that in order to meet the meaningful use objective for computerized provider order entry (CPOE) for medication orders, any licensed healthcare professional can enter orders into the medical record per state, local, and professional guidelines. The remaining meaningful use objectives do not specify any requirement for who must enter information. If an eligible professional (EP) sees a patient in a setting that does not have certified electronic health record (EHR) technology but enters all of the patient s information into certified EHR technology at another practice location, can the patient be counted in the numerators and

20 denominators of meaningful use measures for the Medicare and Medicaid EHR Incentive Programs? Yes for Stage 1, an EP may include patients seen in locations without certified EHR technology in the numerators and denominators of meaningful use measures if the patients information is entered into certified EHR technology at another practice location. However, EPs should be aware that it is unlikely that they will be able to include such patients in the numerator for the measure of the use computerized provider order entry (CPOE) objective or for the e-prescribing measure. CPOE must be entered by someone who can exercise clinical judgment in the case that the entry generates any alerts about possible interactions or other clinical decision support aides. This necessitates that CPOE occurs when the order first becomes part of the patient's medical record and before any action can be taken on the order. Because information for patients seen in locations without certified EHR technology will be transcribed at a later date into the certified EHR system, it is unlikely that CPOE could occur before any action is taken on the order. For the e-prescribing measure, it is unlikely that EPs will be able to electronically transmit prescriptions for patients in locations without certified EHR technology. When an EP starts Stage 2 of meaningful use, this is no longer the case and a location must be equipped with EHR Technology certified to the 2014 edition criteria for patients seen at that location to be counted. Who can enter medication orders in order to meet the measure for the computerized provider order entry (CPOE) meaningful use objective? Any licensed healthcare professional can enter orders into the medical record for purposes of including the order in the numerator for the measure of the CPOE objective if they can enter the order per state, local, and professional guidelines. The order must be entered by someone who could exercise clinical judgment in the case that the entry generates any alerts about possible interactions or other clinical decision support aides. This necessitates that CPOE occurs when the order first becomes part of the patient's medical record and before any action can be taken on the order. E ach provider will have to evaluate on a case-by-case basis whether a given situation is entered according to state, local, and professional guidelines, allows for clinical judgment before the medication is given, and is the first time the order becomes part of the patient's medical record. How should eligible professionals (EPs) select menu objectives for the Medicaid Electronic Health Records (EHR) Incentive Programs? Eligible Professionals (EP) are required to report on a total of 5 meaningful use objectives from the menu set. When selecting five objectives from the menu set, EPs must choose at least one option from the public health menu set. If an EP is able to meet the measure of one of the public health menu objectives but can be excluded from the other, the EP should select and report on the public health menu objective they are able to meet. If an EP can be excluded from both public health menu objectives, the EP should claim an exclusion from only one public health objective and report on four additional menu objectives from outside the public health menu set. We encourage EPs to select menu objectives that are relevant to their scope of practice, and claim an exclusion for a menu objective only in cases where there are no remaining menu objectives for which they qualify or if there are no remaining menu objectives that are relevant to their scope of practice. For example, we hope that EPs will report on 5 measures, if there are 5 measures that are relevant to their scope of practice and for which they can report data, even if they qualify for exclusions in the other objectives. Please note that EPs must have complete certified EHR