CoP for Leveraging Federal Financial Participation (FFP) for Medicaid HIT Activities. September 26, 2014

Transcription

1 CoP for Leveraging Federal Financial Participation (FFP) for Medicaid HIT Activities September 26,

2 CoP for Leveraging FFP for Medicaid HIT Activities Agenda Background & Steering Committee ASTHO FFP Updates Types of FFP Available CoP Priorities Questions Collaboration Next Step & Future Meetings 2

3 Terms Explained CoP - Community of Practice FFP - Federal Financial Participation IAPD - Implementation Advance Planning Documents MMIS - Medicaid Management Information System SMHP - State Medicaid Health IT Plan 3

4 Background & Steering Committee CoP Kick-off Meeting August 22, 2014 (91 Attendees) Provide a collaborative forum for public health agencies to: Identify common barriers and challenges to obtaining FFP for public health related HIT activities Share successful models and approaches used to obtain FFP Establish best practices to identify and coordinate intraagency initiatives and projects that may qualify for funding Develop guidance for HIT Implementation Advance Planning Documents (IAPD) Identify key aspects for successful communications and planning with State Medicaid agencies 4

5 Background & Steering Committee CoP Steering Committee (Current) Dr. Bryant Karras State of Washington, Department of Health Julia Gunn Boston Public Health Commission Dr. Art Davidson Denver Public Health Monica Huang ASTHO Bethany Bradshaw ASTHO Therese Hoyle AIRA Paul Schaeffer AIRA Jim Daniel ONC Daniel Chaput ONC Thomas Novak ONC Sanjeev Tandon CDC 5

6 Recap Overview of the use of FFP for Public Health HIT Activities American Recovery and Reinvestment Act of 2009 (the Recovery Act) Health Information Technology (HIT) in the Medicaid program seven page letter to State Medicaid Directors May 18, 2011 (SMDL# ) 90 % Federal financial participation (FFP) for State administrative expenses related to the program. including System and resource costs associated with State interfaces of a Health Information Exchange (HIE)--(e.g., laboratories, immunization registries, public health databases, other HIEs, etc.) The letter outlines expectations relating to the activities and potential uses of the 90/10 matching funds. 6

7 Recap A Step-by-Step Guide for PHAs Seeking HIT/HIE Funding Via the 90/10 Medicaid Match Step 1: Review CMS Letter SMDL# and CMS Letter SMDL# Step 2: Develop an Interagency Agreement between Public Health and Medicaid Step 3: Drafting of Necessary Documents (P-APD, SMHP, I-APD) Step 4: Collaborate early and often with CMS Step 5: Develop I-APD and Submit to CMS Step 6: Revise I-APD Based on Feedback Received Step 7: Receive Approval Letter from CMS Source: A Step-by-Step Guide for Health Departments Seeking HIT/HIE Funding Via the 90/10 Medicaid Match (90-10 tool revised.pdf) available at: 7

8 ASTHO FFP Updates The ASTHO IDPN Medicaid 90/10 workgroup will be holding an inperson, all-day meeting on November 3 rd. The three major goals for this meeting are to: 1) Review existing materials, identify gaps, and consider how to repackage or modify: IAPDs, MOUs, toolkits, and case studies. 2) Discuss potential target audiences SHOs, Sr Deps, Medicaid Directors, financial officers who needs to know what they don t know? 3) Plan for future meeting with federal partners to communicate what is happening in public health and to identify potential ways for CMS to facilitate public health involvement with Medicaid 90/10 funding. 8

9 Federal Partnerships for Health IT funding Thomas Novak Director of Delivery System Reform Office of the National Coordinator for Health IT

10 Medicaid Funding Options for Health IT HITECH Administrative Funding (90/10 FFP, subject to fair share principle) HITECH Health Information Exchange Funding (90/10 FFP, subject to fair share principle & cost allocation) MMIS Funding (75/25 FFP, subject to fair share principle) 9/26/2014 Office of the National Coordinator for Health 10 Information Technology

11 HITECH Administrative Funding (90/10) 9/26/2014 Office of the National Coordinator for Health 11 Information Technology

12 HITECH Administrative Funding (90/10) Who is using it for what? Washington is using it for on-boarding public health personnel to Meaningful Use Wyoming is using it to configure PopHealth for ecqm reporting to the state Medicaid agencies from Medicaid providers Many states are using it to support Medicaid provider Meaningful Use attestation for targeted purposes (MU2, underrepresented specialists, or generally non-onc eligible providers) 9/26/2014 Office of the National Coordinator for Health 12 Information Technology

13 HITECH Health Information Exchange Funding (90/10) Who is using it for what? 9/26/2014 Office of the National Coordinator for Health 13 Information Technology

14 HITECH Health Information Exchange Funding (90/10) 9/26/2014 Office of the National Coordinator for Health 14 Information Technology

15 HITECH Health Information Exchange Funding (90/10) 9/26/2014 Office of the National Coordinator for Health 15 Information Technology

16 HITECH Health Information Exchange Funding (90/10) Scope of Work for this IAPD: The proposed scope of work for which authorization for 90 percent Federal Financial Participation (FFP) is requested in this IAPD directly correlates to the SMHP submitted to CMS on October 1, This includes funding for the phased development of the Medicaid Gateway to the statewide ***** that will support providers in achieving Meaningful Use. Phase 1: ***** (Directed Exchange Secure Messaging) Continue provider onboarding to providers who want to use Direct to achieve interoperability and meaningful use Phase 2A: Network Services (Query-Based Exchange) Load statewide master patient index(empi) with Medicaid members information Phase 2B: Statewide Medicaid/Public Health HIE Solution Integration Services Continuity of Care Document (CCD) populated from Medicaid claims data (and other data as available) Single Sign on with Medicaid MMIS portal MU reporting 9/26/2014 Office of the National Coordinator for Health 16 Information Technology

17 MMIS Funding (75/25) Seven Standards and Conditions Modularity Standard MITA Condition Industry Standards Condition Leverage Condition Business Results Condition Reporting Condition Interoperability Condition 9/26/2014 Office of the National Coordinator for Health 17 Information Technology

18 MMIS Funding (75/25) 9/26/2014 Office of the National Coordinator for Health 18 Information Technology

19 MMIS Funding (75/25) Who is doing what with it? MA has $10 million plus of their HIE funded with MMIS funds by creating an Medicaidcentric HIE OR is using MMIS funds to connect Medicaid providers using Direct Messaging PDMP (42 CFR (d) ) State Prescription Drug Monitoring Program 9/26/2014 Office of the National Coordinator for Health 19 Information Technology

20 Federal Partnerships for Health IT funding: What hasn t been requested yet? 9/26/2014 Office of the National Coordinator for Health 20 Information Technology

21 Questions 1. I m a state MU coordinator. I ve approached my state Medicaid director with a public health project to include in an IAPD. Based on my understanding from what I have heard in the FFP CoP meetings the project should qualify. The Medicaid Director disagrees. Who/where do I turn to next? Are there clear inclusion / exclusion criteria for projects? Is there state to state variation for similar projects? 21

22 Questions 2. Questions on timing. Is the IAPD on an annual cycle? Roughly, how long might I expect the process to take from initiating conversations with my state Medicaid agency to receiving funding 3. The steps above refer to collaborating with CMS. I ve heard never contact CMS directly, always go through you state Medicaid Director. These steps refer to public health working with their state Medicaid team, right? 4. Should my projects tie to or appear in the State Medicaid HIT Plan (SMHP)? 5. Should my projects tie to or appear in the state HIT plan? 22

23 Questions Is it clearly defined which funds be used for short term operational projects (e.g. onboarding) and which can be used can be used for infrastructure projects (obtaining server/software Rhapsody)? Will the presence, or absence, of a sustainability plan for my program help or hinder funding for my project? 23

24 CoP Communication & Collaboration Space CDC Meaningful Use Mailbox Submit Questions, Suggestions, Intention to share experiences during CoP webinars in the context of jurisdictional IAPDs etc. to include CoP FFP in the subject line. CoP s phconnect Site: Community Discussions and Documents. CoP Monthly Calls- Registration Info, Agenda, Slides are available. 24

25 Next Steps & Future Meetings Rescheduling Meetings for November & December 2014 Future Topics and Community Participation 25

26 Additional Resources CMS FAQ#7809 ( [EHR Incentive Programs] What funding sources may States use to fund the 10% non-federal share of HITECH administrative expenditures? States must fund the 10 percent non-federal share of the Health Information Technology (HITECH) Act administrative expenditures consistent with the law and regulations applicable to the non-federal share for all Medicaid expenditures. Consistent with that authority, which includes Social Security Act sections 1902(a)(2), 1903(a), 1903(w), and 42 CFR Part 433, subpart B, states may fund the non-federal share of Medicaid expenditures through legislative appropriations to the Medicaid agency, intergovernmental transfers (IGTs), certified public expenditures (CPEs), permissible health-care related taxes, and bona-fide donations. States must submit their proposed strategies for funding the non-federal share of HITECH administrative payments to CMS for review as part of the HIT plan approval process. CMS will review each individual State s proposal to ensure that each proposed nonfederal share funding source meets federal requirements. During this process, CMS can address specific questions about funding the non-federal share of Medicaid expenditures. CMS strongly urges States to work on their funding proposals with their CMS HIT Coordinators as early as possible before claiming for HITECH administrative expenditures, to ensure funding structures are appropriate. HITECH administrative expenditures, like other title XIX expenditures, are subject to audit, and federal funds may be at risk if funding sources are found not to be in compliance with federal requirements. Below are some statutory and regulatory citations pertaining to non-federal share financing requirements. Please note this is not an all-inclusive list of funding requirements. Use of Federal Funds o Social Security Act 1903 o 42 CFR (c) State Appropriations o Social Security Act 1902(a)(2) o 42 CFR Certified Public Expenditures o Social Security Act 1903(w)(6)(A) o 42 CFR Healthcare-Related Taxes and Provider-Related Donations o 42 CFR part 433, subpart B Intergovernmental Transfers o Social Security Act 1903(w)(6)(A) o 42 CFR

27 Additional Resources CMS FAQ#3113 ( ) [EHR Incentive Programs] Can a State access enhanced matching funds for the Medicaid EHR Incentive Program to participate in the creation of a Health Information Exchange (HIE) that is not directly administered by the State Medicaid Agency? The enhanced match rate depends upon whether the Health Information Exchange solution is using Medicaid Management Information System (MMIS) funding or Health Information Technology for Economic and Clinical Health (HITECH) funding. Governance only is relevant under the MMIS regulations, as it pertains to the matching rate determination. States should talk to CMS about their ideas in draft, informally, so that CMS can give a more State-specific response around appropriate funding, matching rates, etc. 27