Frequently Asked Questions

Transcription

1 Frequently Asked Questions Florida Medicaid Electronic Health Record Incentive Program March 9, 2015 Version 4.2 For additional assistance please contact the Florida EHR Incentive Payment Program Call Center at (855) or 1

2 Table of Contents Part 1: OVERVIEW Updated Part 2: ELIGIBILITY Eligible Professionals Updated Part 3: ELECTRONIC HEALTH RECORD (EHR) SYSTEMS Part 4: HEALTH INFORMATION EXCHANGE Part 5: HOSPITALS Updated Part 6: MEANINGFUL USE Updated Part 7: PARTICIPATION Part 8: REGISTRATION Part 9: PAYMENTS Part 10: PUBLIC HEALTH Updated Part 11: CERTIFICATION FLEXIBILITY RULE Part 12: ACRONYMS 2

3 PART 1: OVERVIEW 1. What is the Florida Medicaid Electronic Health Record (EHR) Incentive Program? The Florida Medicaid EHR Incentive Program provides incentive payments to eligible professionals (EP) and eligible hospitals (EH) as they adopt, implement, upgrade (AIU), and demonstrate meaningful use (MU) of certified electronic health record technology (CEHRT). EPs can participate in the program for up to six years but must begin participation by EHs can participate in the program for up to three years and also must begin participation by EPs and EHs are not required to participate in consecutive years and there is no Medicaid financial penalty for providers that choose not to complete the entirety of the program. The program was launched on September 5, 2011, and is scheduled to continue through In Florida, the Agency for Health Care Administration (Agency) is administering the EHR Incentive Program in accordance with the federal government guidelines. The program is funded through the provisions in the American Recovery and Reinvestment Act (ARRA), in a section known as the Health Information Technology for Economic and Clinical Health Act (HITECH) Act. Provider payments are funded 100% by federal funds. The goal of the program is to promote the adoption and meaningful use of CEHRT by providers. This activity is a building block to the larger vision of health information technology (Health IT) as a platform that serves to improve communication between patient and provider, empower patients to be more involved in their healthcare choices, improve quality and safety by a reduction in errors, and promote cost-containment through improved coordination. The last year for EPs and EHs to begin participating in the EHR Incentive Program is EPs participating for the first time in program year 2016 must meet all requirements by December 31, 2016 and submit their application by the end of the grace period for program year EHs participating for the first time in program year 2016 must meet all requirements by September 30, 2016, and submit their application by the end of the grace period for program year What do the timeframe terms mean? Payment year refers to the year of EP or EH program participation e.g. year one. Program year refers to the calendar year of program participation (e.g. 2013, 2014, etc.) for EPs and the federal fiscal year for EHs. Volume reporting period refers to the consecutive, 90-day period used to meet Medicaid patient volume requirements. During the volume reporting period, a provider does not have to be using certified technology. Reporting Period (also known as the MU attestation timeframe) refers to the period of time that the EP or EH is documenting actual use of CEHRT and meeting specified measures and thresholds. 3. What are the different requirements between Adopt, Implement, and Upgrade (AIU) and Meaningful Use (MU)? Through the Medicaid EHR Incentive Program, providers have the option of applying for their first year incentive payment by demonstrating that they have adopted, implemented, or upgraded (AIU) to CEHRT. Providers are not required to have actually implemented or be using CEHRT to qualify for AIU payment, but they must have possession of the CEHRT. It cannot be a planned upgrade or procurement. Providers may also choose to skip AIU attestation and move straight to MU attestation. Providers participating in the Medicare Incentive program do not attest to AIU, only MU. 3

4 In order to qualify for MU payments, providers must demonstrate that they have been using CEHRT in a meaningful way by meeting specific MU measures and objectives. MU measures and objectives, including the thresholds for compliance, were set forth in federal legislation. 4. What are the Stages of Meaningful Use (MU)? Currently there are two stages of MU. Providers attest to two years of each MU stage, even if the payment (participation) years are not consecutive. For the first payment year of Stage 1 MU, providers will report on MU requirements for a continuous 90-day reporting period within the program year for which they are participating. For the second payment year, providers will continue to meet and report on Stage 1 MU requirements for a full calendar year. EXCEPTION: In 2014, all providers will have a 90-day reporting period regardless of whether attesting to Stage 1 or Stage 2 MU. After completing two years of Stage 1 MU, providers advance to Stage 2 MU requirements. Stage 2 MU requirements place greater emphasis on patient engagement and exchange of health information. Providers will only advance to Stage 2 MU after completing the two reporting periods of Stage 1. Stage 3 requirements are in the process of being finalized and will be effective October 1, 2016, for EHs and January 1, 2017, for EPs. Part Six contains details on Meaningful Use requirements, measures, and thresholds. 5. Can someone attest on my behalf? Providers and hospitals that allow someone to attest on their behalf must establish the relationship on the CMS registration and attestation system (EHR Incentive Program Registration site). The creation of the federal level relationship will allow a user to access and manage the registration on behalf of a provider or hospital. The state application is available via the provider s individual Medicaid provider portal. A provider must authorize a user to work on their behalf within the Medicaid provider portal. To establish this relationship, contact the EHR Call Center at (855) The preparer should indicate their relationship with the provider on MAPIR (the online state application) under the submit tab. 6. How long should I keep records supporting my EHR program applications? All documentation supporting the application should be kept for a period of six years from the date of the incentive payment. This includes back-up information submitted with the application. Providers are encouraged to keep documentation to support measures, including numerical data and support for yes/no measures. For example, a screen shot of a patient which triggered a drug-drug interaction can document compliance with this measure. Summaries as well as detailed information on patient counts should be included in maintained documentation. Documentation supporting the numerator and denominator of the MU measures (core, menu, and Clinical Quality Measures (CQMs) must be included with the application. Documentation recommendations include: Back up reports with hard copies reports cannot always be recreated later Screen shots of yes/no answers and other system functionality, with dates o It is recommended that screen shots are taken throughout the EHR reporting period to satisfy the requirement that the functionality is in effect during the entire reporting period. Details on the Security Risk Assessment (SRA) ensure that you have a written account of the findings as well as any action taken to mitigate findings If you rely on an FAQ interpreting how you met a meaningful use measure, keep a copy of the FAQ with the effective date of the FAQ or the date you referenced the FAQ. Document the reasons for claiming an exclusion. 4

5 7. What, if any, types of audits will be conducted on incentive payments received? The Agency is required to perform provider audits to ensure that incentive payments were made to EPs that met all program requirements. The Agency has contracted with KPMG, LLP (KPMG), a public accounting and auditing firm, to conduct these post-payment audits. Providers will initially be notified by the Agency of their selection for audit. Within five business days, KPMG will contact the provider directly with a list of requested documentation and information on how to submit. Audits will be conducted on AIU and MU attestations. The documentation requested will vary based on the type of the audit. AIU documentation requested may include detailed patient level volume reports, the employment contract (if payment was assigned to a group), and additional supporting documentation of AIU, to the certified EHR system. MU audits will focus more on the actual measures, but will also include volume, employment status, and system capabilities. If selected for an audit, providers are encouraged to respond within the time periods specified. Subsequent incentive program applications from the provider, and/or any member of the group with whom the provider is associated, will be held until audit disposition is complete. In addition to audits conducted on behalf of the Agency, the Florida Auditor General, the Centers for Medicare and Medicaid Services (CMS), and the Federal Office of the Inspector General (OIG) may conduct audits of EHR incentive payments. 8. What documentation should be included with my application? The documents listed below must be uploaded as part of the application process. Providers should maintain complete documentation supporting the application. Uploaded documents must be in PDF format and can be uploaded while the application is in either Incomplete or Submitted status. Large and/or numerous documents can also be zipped and uploaded. If the application is submitted without any documentation attached, an error message will appear reminding you that documents must be attached. The error message does not validate the type of documents rather just that documentation has not been provided. ALL APPLICATIONS: Copy of the Practice Management Report supporting your volume ADOPT, IMPLEMENT, or UPGRADE (AIU) Documentation that supports the AIU of the certified technology MEANINGFUL USE (MU) MU Measure report for the EHR reporting period including core, menu, and clinical quality measure (CQM) information Additional Documentation Form Documentation from Florida Shots, if not excluding because you provided no immunizations Note: If MU information is pulled from different systems for the EHR reporting period, then reports from all systems used must be uploaded. AS APPLICABLE Volume Workbook recommended if using unpaid, denied or never billed Medicaid encounters Physician Assistant (PA) Led Attestation Form Advanced Registered Nurse Practitioners (ARNPs) or PAs billing under a supervising physician must include a copy of a medical record supporting your provision of a Medicaid service 5

6 9. Will there be always be a grace period for each Program Year? Yes. The program year for EHs is the federal fiscal year: October through September. The grace period for EHs extends through December 30 th following the end of each program year. The program year for EPs is the calendar year: January through December. The grace period for EPs extends through March 31 st following the end of each program year. The grace period is only applicable for applicants that have completed program requirements by the end of the program year. There is an exception for the 2014 program year. The grace period for EHs will extend through January 31, The grace period for EPs will extend through June 30, Have there been changes that affect access to Medicaid provider portal accounts? Yes. Security changes to Medicaid provider portal have been implemented. All accounts not logged into for 120 days or more will be locked due to inactivity. Agent accounts (those that can access the Medicaid provider portal on behalf of the provider) which have been locked for more than 120 days will be terminated resulting in the deletion of that account. A deleted account cannot be restored so a new account will have to be created and associated to any pre-existing applications. It may take several weeks to create and associate a new Medicaid provider portal account. If you have issues logging into your Medicaid provider portal account, please contact Provider Services at It may take a few weeks for you to regain access. The instructions below detail the steps you need to follow to complete reactivation of a locked account. Reactivation procedure: 1. Enter the username in the Username field on the log in page of the secure portal ( 2. Click on "Forgot your password?" 3. Re-enter the "username" and " " associated with the account. You must use the account that was used to register for your account or you will receive an error message 4. A "PASSWORD RESET" will be sent 5. Click on the link and answer the security question that was created when the account was initially established 6. Once the security question is successfully answered, you can create a new password and access your secure portal account. If a different person will be completing the state on-line application (MAPIR) than in previous program years, the User ID attached to the MAPIR application may need to be changed. After the preparer gains access to the secure Medicaid Portal, if the preparer does not see the EHR Incentive link, the User ID may need to be updated. Please contact the EHR call center at for assistance with updating the User ID. 11. How do all the deadlines I see published affect my participation? Many of the published deadlines released by CMS are Medicare related. When participating in the Medicaid Incentive Program, the key deadlines are: The EHR (aka MU) reporting period must end by December 31 st of the calendar year in which you are reporting. Each Program Year application must be filed by the stated grace period application for that year. 12. Is documentation needed to prove that 2014 CEHRT has been used? Yes. A letter is needed from the vendor indicating the provider s name or practice name, the name and version of the system, certification number, and date of implementation. 6

7 13. Is there a 90 day reporting period in 2015? New CMS is considering changes for the 2015 Program Year including adjusting the reporting period to 90 days, and aligning the hospital program year to a calendar year. The changes have not been finalized. The Agency will not be making policy or system changes until the rule has been finalized and issued by CMS. Providers scheduled to report full year meaningful use in 2015 are encouraged to continue working towards meeting measures for the full year including having functionality enabled continuously. 7

8 Part 2: ELIGIBILITY Eligible Professionals (EPs) 1. Who is eligible for the Medicaid Electronic Health Record (EHR) Incentive Program? Non-hospital-based physicians Dentists Advanced Registered Nurse Practitioners (ARNP) Certified nurse midwives Physician assistants must be working in a Federally Qualified Health Center (FQHC) or Rural Health Clinic (RHC) and that clinic is led by a physician assistant. 2. How is hospital based status determined? Hospital based is defined as 90% or more of encounters occurring in an inpatient or emergency room setting (place of service 21 or 23). Processing staff validate non-hospital based using Medicaid encounters from the calendar year prior to the program year. If 90% or more of the provider s Medicaid encounters were at place of service 21 or 23, the previous federal and state fiscal years are reviewed, in an attempt to qualify the provider. If 90% or more of the EP s Medicaid encounters are hospital based, but their total encounters are less than 90% in hospital or emergency room locations, the provider can meet this requirement by uploading documentation from the practice management system of encounters by place of service. The time period for the report should be the calendar year prior to the program year. PATIENT VOLUME 1. What is the Medicaid patient volume requirement? Eligible Professionals* Physician (MD, DO) Dentist Certified Nurse Midwife Nurse Practitioner Physician Assistant (PA) in a RHC or FQHC led by PA Pediatrician** Medicaid Patient Volume Over 90-Day Period 30% Medicaid 30% Medicaid 30% Medicaid 30% Medicaid 30% Medicaid 20% Medicaid *Eligible professionals practicing at least 50% of the time in an RHC or FQHC can count needy individuals when determining patient volume. ** Pediatricians who qualify with a 20% Medicaid patient volume receive two-thirds of the maximum incentive payment, totaling $42,500. Providers must meet the volume requirement for each payment year. Volume percentages can be rounded up based on standard rounding, e.g. 29.6% could be rounded up to 30%. 2. What can I use to determine my Medicaid volume? Updated Patient volume is based on encounters. Encounters are defined as services provided to a single patient on a single day. The denominator is all patient encounters, regardless of whether the encounter is billed or paid. Each date of service is only counted once. Medicaid encounters are defined as services rendered on any one day to an individual enrolled in a Medicaid program. It is no longer required that the encounter be paid in order to include it in Medicaid 8

9 volume determination. This includes: o services to Medicare/Medicaid dually eligible individuals; o services to those with primary third party payers; o services rendered to a Medicaid patient but not billed; and o services denied, unless the denial reason is that the individual was not enrolled in Medicaid on the date of service. Persons enrolled in Medicaid managed care plans e.g. Amerigroup, First Coast Advantage, Humana, etc., and Medicaid Provider Service Networks should be included in volume calculations. Volume is calculated by dividing Medicaid encounters by the total number of patient encounters. Each date of services rendered to an individual patient should only be counted once. Updated At least one clinical location used in the calculation of patient volume must have certified EHR technology (CEHRT). If you are adopting CEHRT, it is not required that the technology be in use. Providers have the option to determine volume based on a continuous 90-day period in the calendar year prior to the program year or a continuous 90-day period in the 12 months prior to the application date. The 90-day period can span calendar years when using a 90-day period in the 12 months prior to the application date. The option for the 12 months prior to the application date is a rolling period of time that changes each day. 3. How is volume determined individually or based on my group? If you are an individual practitioner, you calculate the percentage of total individual Medicaid encounters over total individual practice encounters. Total Individual Medicaid Encounters Total Individual Practice Encounters If you are a member of a group practice, you have two options: Option One: All members of the group will use group Medicaid volume this is also known as group proxy. Total Group Medicaid Encounters Total Group Encounters Option Two: All members of the group will use their individual Medicaid encounters from the group (use individual formula). Pediatricians can choose to qualify with 20 29% Medicaid volume in any of these examples, but will only receive 2/3 of the maximum payment. 4. How is volume validated? Eligible professionals (EPs) are requested to upload a copy of their Practice Management System (PMS) or other billing system report that indicates the number of encounters by payer as well as totals for all payers. This report should delineate the individual provider of service if using individual volume. The reported volume, as well as the information from the PMS report, is validated against data in the Medicaid system. Please note that the PMS or billing system is often a separate system from the EHR and that is acceptable. Also, if a practice does not have a billing system that can generate the volume numbers, this documentation can be provided through the manual creation of a report. If you have a question about how these numbers are obtained for your practice, please contact the EHR Call Center at 1 (855) for further clarification. 9

10 Providers still have the option of basing volume solely on Medicaid paid claims. If including denied or never billed claims for patient volume, providers are encouraged to utilize the Volume Workbook. The use of this worksheet will expedite the pre-payment validation process since it will direct staff on how the numbers were calculated. The worksheet is available via the website under Volume Workbook. 5. What is meant by needy volume and can I include these individuals in my volume? Only providers practicing in an FQHC or RHC at least 50% of the time can include needy individuals in their volume calculation. Needy individuals are defined as those that: Received medical assistance from Medicaid or the Children's Health Insurance Program (CHIP) (or a Medicaid or CHIP demonstration project approved under section 1115 of the Act) Were furnished uncompensated care by the provider Were furnished services at either no cost or reduced cost based on a sliding scale determined by the individuals' ability to pay 6. Can Healthy Kids or MediKids be included in patient volume? Healthy Kids and MediKids are eligibility groups under the Child Health Insurance Program (CHIP). Unless the provider is working in an FQHC or RHC and can include needy individuals, encounters for Healthy Kids or MediKids do not qualify as Medicaid encounters. CHIP is funded under Title XXI, not Medicaid Title XIX. Although claims for MediKids are billed to Medicaid for adjudication, they are not paid for by Medicaid funds. 7. Since I can choose my volume period, can I use the same volume period for both a Program Year 2013 application and a Program Year 2014 application? For example, if a provider applies in June of 2013 and uses the volume period March May of 2013, can that same volume period be used for a Program Year 2014 application? No. Each program year requires meeting the volume using a completely different period of time. MAPIR has been programmed to prevent a provider from selecting volume dates that overlap a volume period the same provider previously used. PROVIDER TYPES 1. How does Florida define pediatrician for purposes of the EHR Incentive Program? Pediatricians are physicians with a specialty in pediatrics. Physicians declare their specialty when they enroll in the Florida Medicaid program. Pediatricians may be eligible for incentive payments if their Medicaid volume is between 20% and 29% of their total volume. To be eligible for an incentive payment as a pediatrician with Medicaid volume between 20% and 29%, physicians must have the Specialty Code 035, which specifies Pediatrics, on their Medicaid provider file. A physician may also have other specialty codes. Attestation to the specialty type must be submitted to the Medicaid fiscal agent before the eligible professional applies to participate in the EHR Incentive Program. Please note, if you are a pediatrician attesting to 20% to 29% Medicaid volume, make sure you select pediatrician for your provider type in MAPIR. Selecting physician and reporting volume under 30% will cause your application to be denied.. 2. Can a pediatric nurse practitioner or physician assistant qualify for the program with 20-29% Medicaid volume? No. Only physician providers with a pediatric specialty can qualify with the lower volume. 10

11 3. As an ARNP, the majority of my services are billed using the supervising physician s billing information. Can I apply for a payment? Yes, ARNPs are defined as EPs for the EHR Incentive Program and can receive an incentive payment. ARNPs can apply using group volume, their individual Medicaid volume from the group, or their supervising physician s individual volume from the group for services the ARNP rendered. USING INDIVIDUAL VOLUME: The application must contain the practice management system (PMS) or billing report indicating the volume attributable to the applicant ARNP. USING GROUP VOLUME: When an ARNP is using group volume, there must be at least one paid Medicaid encounter between the start of the 90-day volume reporting period and date of attestation/application. USING SUPERVISING PHYSICIAN VOLUME: A. The volume reporting period for the ARNP must be distinctly different from the volume reporting period for the supervising physician when using individual volume as well as any other ARNP that may be using the supervising physician volume. For example, if a physician supervises ARNP A and ARNP B, there must be a distinct 90-day period for the physician, a distinct 90-day period for ARNP A, and a distinct 90-day period for ARNP B. B. The PMS or billing report must include encounters for the applicant ARNP, the supervising physician, and all other ARNPs under that physician s supervision. C. The application must also contain documentation of one paid Medicaid encounter as evidenced by a medical record. The medical record must contain: name and Medicaid number of the recipient; the date of service; the services rendered; the location of the services being rendered; and the signature of both the ARNP and supervising physician. 4. What is meant by a PA-led clinic? A Physician Assistant (PA) would be leading an FQHC or RHC under any of the following circumstances: When a PA is the primary provider in a clinic (for example, when there is a part-time physician and fulltime PA, the PA would be considered the primary provider); When a PA is a clinical or medical director at a clinical site of practice; or When a PA is an owner of an RHC. PAs completing applications will be asked to complete the Attestation for Physician Assistant Led form available on the EHR Incentive Program Website. This form will delineate how the PA meets the definition of practicing in a PA-led clinic. The form can be found at PA Led Attestation Form. As part of the pre-payment validation process, claims history is reviewed as well as information contained on the Medicaid provider file. In order to be considered PA led, the number of encounters with the PA as the rendering provider should greatly exceed the number of encounters with the physician and any other providers as the rendering provider. 5. Are residents eligible to participate in the EHR Incentive Program? Yes, if the resident is a fully enrolled Medicaid provider. Only residents that have been issued a full license are eligible to enroll as a Florida Medicaid provider. 6. Are Optometrists eligible to participate? No. The federal rule for the Medicaid EHR Incentive Program limits payments to doctors of medicine and osteopathy. Optometric services are not considered physician services under Florida statue or in the Florida Medicaid state plan. Therefore, this provider type is not eligible for the program. Doctors of Optometry can qualify for participation in the Medicare Incentive Program. 11

12 7. What does it mean to be a fully enrolled Medicaid provider? Fully enrolled is a term used for providers who participate in Medicaid either as a fee-for-service provider or member of a fee-for-service group. If Medicaid has paid you directly for a fee-for-service claim, you are fully enrolled. If you are part of a Medicaid health plan network, you may be registered with Medicaid as a treating provider, but not fully enrolled in Medicaid. With the move to managed care, providers and practices may not have any fee-for-service encounters. Providers and practices must update their Medicaid provider files with any address and contact changes to ensure that requests to re-enroll are received. You must be fully enrolled in the Florida Medicaid program to participate in the EHR Incentive Program. If your Medicaid provider number is terminated for not re-enrolling, you will have to reapply and have the new Medicaid number activated, or you won t be able to access the MAPIR application. Providers can fully enroll in the Florida Medicaid program using the online Enrollment Wizard, downloading the Provider Enrollment Application from the Internet, or requesting an application using the phone number provided below. Once submitted, the completed application and all applicable forms will be reviewed for accuracy. Upon completion of the enrollment process, approved providers are issued a nine-digit Medicaid provider number and a PIN. Please see Guide for Completing a Medicaid Provider Enrollment Application located at under Public Information for Providers, select Enrollment, or call , Option 4, for a complete list of required enrollment documentation. GROUP PRACTICE 1. What is the definition of a group? A basic definition of group is how the provider bills Medicaid for services. In most instances, this will be the Medicaid Group ID. This definition is not intended to be limiting; therefore, providers will have the option of requesting an exception to define their group within the following parameters: There must be an established relationship to the group within the Florida Medicaid Management Information System (provider file); and The documentation of the parameters of the group must be auditable; The Medicaid IDs that comprise the group must have a common Tax ID; or common National Provider Identification (NPI); or common seven-digit base Medicaid ID. 2. What encounters should be included in the group volume calculation? All encounters during the 90-day volume reporting period should be included in your group calculation, including encounters for providers who are no longer associated with the group, providers who will not be applying for a Medicaid incentive payment, and encounters that occurred at locations other than the office. Group volume (also known as group proxy) is determined by how you bill for Medicaid services. For example: Scenario A: All providers and locations associated with the Group bill for Medicaid services under ONE Medicaid number. Group Volume: All encounters across all locations and among all providers would be included. Scenario B: All providers within a location bill for Medicaid services under a Medicaid number that is specific to that location. Group Volume: Encounters associated with that location would be included. This is true even if the individual locations pay to one group NPI. 12

13 Scenario C: The practice has more than one location. Each location has a unique Medicaid ID. Each location has the same Tax ID and may or may not have the same group NPI or seven-digit base Medicaid ID. Group Volume: The practice can use just one of the group s Medicaid IDs or all of the group s Medicaid IDs. If the practice has five different Medicaid ID s, the practice cannot pick two of the five, the practice must use just one or all five. If one provider in the group uses group volume, all providers in the group are required to use the group volume UNLESS an individual provider is applying using their volume from a different location not affiliated with the group. In this case, the individual provider would not be able to use encounters associated with the group. 3. What conditions must be met to use group volume? To use group volume, the group must meet the following conditions: The clinic or group practice's patient volume is appropriate as a patient volume methodology calculation for the EP; There is an auditable data source to support the group's patient volume determination; The EP in the group decide to use one methodology in each payment year (in other words, groups could not have some of the EP using their individual patient volume for patients seen at through the group, while others use the group level data); and The group must use the entire practice's patient volume and not limit it in any way; The EP using group volume must have had at least one Medicaid encounter between the start of the 90-day volume period and the date of attestation. It is no longer required that the encounter be paid. The group must be recognized as a group within the Medicaid system and must be following group billing practices during the volume-reporting period. 13

14 Part 3: ELECTRONIC HEALTH RECORD (EHR) SYSTEMS 1. How can it be determined whether an EHR is certified? Providers must have access to or be using Certified Electronic Health Record Technology (CEHRT) as one condition of eligibility for the EHR Incentive Program. The Office of the National Coordinator (ONC) has established an Authorized Testing and Certification Body (ONC-ATCB) to review and certify systems. The Certified Health IT Product List is available at Certified Health IT Product List (CHPL). The certification number from the CHPL is required for the online application. Beginning with Program Year 2015, all providers must be using 2014 CEHRT to participate in the incentive program. 2. Can an eligible professional (EP) use EHR technology certified for an inpatient setting to meet a meaningful use (MU) objective and measure? Yes. For objectives and measures where the capabilities and standards of EHR technology designed and certified for an inpatient setting are equivalent to or require more information than EHR technology designed and certified for an ambulatory setting, an EP can use the EHR technology designed and certified for an inpatient setting to meet an objective and measure. 3. Does a provider such as a dentist who has access to a certified EHR system qualify? As long as the provider has access to a certified EHR system that is capable of meeting MU objectives, they may qualify. In the case of dentists, many have a dental system that is interfaced with a certified EHR system; the provider would need access to all parts of the certified EHR system to qualify. 4. Will the Agency need to verify the "installation" or "a signed contract" for adopting, implementing, or upgrading a certified EHR system? Yes, as part of the application process for first year payments, a letter is needed from the vendor indicating the provider s name or practice name, the name and version of the system, certification number, and date of implementation. 5. Can a provider still qualify when using a free EHR system? If documentation of a licensing arrangement cannot be obtained from the vendor, the following documentation should be included as proof that the provider/practice has access to the system: A copy of page one of the license agreement A screenshot from the EHR system indicating the software s name and version A copy of the EHR system s screen that displays, at minimum, the provider s name and the name of the free software (usually a header at the top of each screen) In addition, if access to the EHR system is through an arrangement with another individual or organization, a copy of the agreement between the owner of the system and the applicant that indicates the name and version of the software must be included. 14

15 Part 4: HEALTH INFORMATION EXCHANGE (HIE) 1. Can Protected Health Information (PHI) be sent through a regular account No. PHI transmitted over the internet must be encrypted. Many electronic health record (EHR) systems contain a secure feature that allows providers to safely exchange patient information through encrypted messaging services. Talk with EHR vendors to learn about the services they offer. 2. My EHR system has a secure feature. How can I use it to send s to other providers that also have a secure feature? Check with your vendor to determine if connections have been established with other EHR systems. 3. I have been told that my EHR system s secure feature is DirectTrust Accredited. What does that mean? New DirectTrust is a not-for-profit entity that has established a framework to support the exchange of health care information between disparate EHR systems using the Direct protocol. If your EHR system s capability is DirectTrust accredited, you should be able to other health care providers who use a DirectTrust accredited services regardless of EHR vendor. This includes providers using the Florida HIE Direct Messaging Service which is DirectTrust accredited. 4. What services are available through the Florida Health Information Exchange (Florida HIE)? The Florida HIE operates a variety of services including: Patient Look-Up (PLU) - a network of networks that allows health care organizations to query the medical records (with patient consent) of other participating health care organizations for individual patient data. o Some of the PLU participants offer a hybrid service allowing non-affiliated providers to obtain patient information from the PLU service. Event Notification Service (ENS) - provides health plans with expedited notifications on their members hospital encounters. Direct Messaging - encrypted, Direct Trust accredited service that allows providers to securely exchange messages and patient information electronically. For more information, please visit 15

16 Part 5: HOSPITALS 1. What are the Medicaid Electronic Health Record (EHR) Incentive Program requirements for hospitals? Acute care hospitals (including Critical Access hospitals and cancer hospitals) with at least 10% Medicaid patient volume and an average length of stay of 25 days or less are eligible for the Medicaid EHR Incentive Program. Children's Hospitals are eligible but are not required to meet Medicaid volume requirements. 2. Can a hospital participate in both the Medicare and Medicaid Incentive Programs? Yes. Hospitals can receive payments from both the Medicare and Medicaid Incentive Programs if they meet requirements for both. Hospitals that are dually eligible should select Both Medicare and Medicaid during the federal registration process. Hospitals participating in multiple states must choose only one payment state for the Medicaid program. 3. How is the 10% Patient Volume calculated for Medicaid hospital eligibility? The calculation for patient volume is the total Medicaid patient encounters in any representative continuous 90-day period in the previous hospital fiscal year divided by total patient encounters in that same 90-day period]* 100. NOTE: Hospitals have the option to determine volume based on a 90-day period in the previous hospital fiscal year or a 90-day period in the previous 12 months preceding application. For purposes of calculating hospital patient volume, the Centers for Medicare and Medicaid Services (CMS) has allowed the following to be considered Medicaid encounters: Services rendered to an individual per inpatient discharges where the patient is a Medicaid recipient on the date of service; Services rendered to an individual in an emergency department on any one day where the patient is a Medicaid recipient on the date of service. Medicaid inpatient discharges and Medicaid emergency department encounters, as defined, would be added together as the numerator and all inpatient discharges and emergency department encounters would be added together as the denominator. 4. When do Hospitals have to demonstrate Meaningful Use (MU) for the Medicaid EHR Incentive Program? Hospitals applying for a first year Medicaid incentive payment do not have to demonstrate MU as long as they have not attested for a Medicare incentive payment. They only have to demonstrate that they have adopted, implemented, or upgraded (AIU) certified EHR technology (CEHRT) and there is no reporting period for this requirement. Once a hospital attests to MU with Medicare they will be deemed a meaningful user for Medicaid. 5. How is the total Medicaid hospital incentive payment calculated? The hospital incentive payment is based on a formula that calculates an aggregate incentive payment at the time a hospital initially enrolls in the program. Further details about the formula and a template to assist hospitals in the calculation are available at Hospital Payments Documents. 6. How will the incentive payments to Florida hospitals be distributed across participation years? The Florida Medicaid program will distribute payments over 3 years based on the following percentages: Participation Year 1: 50% of Aggregate EHR Hospital Incentive Amount Participation Year 2: 40% of Aggregate EHR Hospital Incentive Amount Participation Year 3: 10% of Aggregate EHR Hospital Incentive Amount 16

17 7. When is the last year a hospital can begin receiving payments from the Medicare and Medicaid EHR Incentive Programs? Updated For Medicare, the last year a hospital can receive a payment is federal fiscal year (FFY) Hospitals can begin receiving payments from FFY 2011 to FFY However, the incentive payment will decrease for hospitals that start receiving payments in 2014 and later. Hospitals that are not meaningful users of Certified EHR Technology will be subject to payment adjustments in For Medicaid, hospitals must begin receiving EHR Incentive Payments by Program Year Hospitals receiving a Medicaid EHR Incentive Payment must receive payments on a consecutive, annual basis after I received a payment last year for AIU. What do I do to get my 2 nd year payment? Hospitals that received an AIU payment are required to attest to and meet meaningful use measures for the second payment. If you are a Medicare/Medicaid hospital, then the information and reporting period submitted to Medicare will be transferred to the State and will serve as your attestation to MU. You will be required to complete the online MAPIR application. As part of the State application, you will be required to enter your patient volume numbers to meet the 10% Medicaid volume requirement for the Medicaid incentive program. Your second year payment will be 40% of your total calculated payment. 9. I am a dually eligible hospital and have already received a Year One payment from Medicare. Can I still do AIU for Medicaid? No. Once you have received a payment from Medicare attesting to meaningful use, you are deemed a meaningful user and are required to report meaningful use for Medicaid as well. Acknowledgement of the information supplied to Medicare will be transferred to Medicaid. Eligible hospitals will still be required to report Medicaid volume each payment year in the Medicaid program. Once a hospital has received an incentive payment for a 90-day reporting period, whether for Medicare or Medicaid, they will have to complete a 365-day reporting period for the subsequent years of participation except for 2014 which only requires a 90-day reporting period. If a hospital wants to receive their first incentive payment for Adopt, Implement, Upgrade (AIU) from the Medicaid Incentive Program, it is important that they complete their Medicaid application process and receive payment before they attest for a Medicare incentive payment. Once a hospital attests for a Medicare incentive payment, they will be deemed a meaningful user and not be allowed to complete a Medicaid attestation for AIU. See CMS FAQ #2715 for additional information on the different reporting periods. 10. For MU payments, do I have to apply with Medicare and report my MU measures prior to completing my State application? As a dually eligible hospital (Medicaid/Medicare) the Medicare attestation should be completed prior to submitting your state application for a MU payment. This will ensure that acknowledgement of the information supplied for MU is readily available for transfer to the state. 11. If a hospital receives their first payment in 2012 for AIU, when can they apply for a MU payment? If a hospital receives a 2012 Medicaid payment (first payment year FFY 2012) for AIU based on 2011 information, and they have not attested for a Medicare incentive payment, then the first MU payment would be based on a 90 day MU period from FFY 2013 and application could be as early as January The second MU reporting period of 365 days would be from FFY 2014 and application could be made beginning October

18 12. Are Medicaid Eligible Hospitals subject to payment adjustments or penalties if they do not adopt certified electronic health records technology or fail to demonstrate meaningful use? There are no payment adjustments or penalties for Medicaid providers who fail to demonstrate meaningful use. However, Medicare Subsection (d) hospitals that are not meaningful users will be subject to a payment adjustment beginning on October 1, For the most up to date information, please refer to Payment Adjustments and Hardship Exemptions. 18

19 Part 6: MEANINGFUL USE 1. What is Meaningful Use (MU)? Updated Meaningful use (MU) describes the activities an eligible professional or hospital engages in to use electronic health records in a way that improves care and service to their patients. The Center for Medicare and Medicaid Services (CMS) established the rule for MU that includes a set of standards, implementation specifications, and certification criteria for electronic health record (EHR) technology. To view the final rule, visit There are three stages of MU: Stage 1 requirements are the standards that providers must currently meet Stage 2 is effective with program year 2014 a. All eligible professionals and hospitals will have two reporting periods of meeting Stage 1 requirements before progressing to meeting Stage 2 requirements Stage Three is effective with Program Year 2017 and specific requirements are still being finalized. 2. Can I implement an EHR system and satisfy MU requirements at any time within the calendar year? The initial 90-day MU period for EPs must be within the calendar year for which you are applying. For example, if applying for a 90-day MU payment for the 2014 program year, the 90-day period must be within For all other years of participation, the EP must demonstrate MU for an entire calendar year. If a provider elects to end their reporting period December 31 st, then the application can be submitted during the grace period. 3. Do specialty providers have to meet all of the MU objectives for the incentive program, or can they ignore the objectives that are not relevant to their scope of practice? All eligible professionals (EPs) who participate in the Medicaid EHR Incentive Programs must meet all of the meaningful use objectives; however, certain objectives do provide exclusions. If an EP meets the criteria for that exclusion, then the EP can claim that exclusion during attestation. Failure to meet the measure of an objective, or to qualify for an exclusion for the objective, will prevent an EP from successfully demonstrating MU and receiving an incentive payment. 4. Can I use group numbers in proving MU? No, MU is based on the individual EP. It is important that each practitioner access the certified EHR under their own login information so that the EHR system can capture the necessary information for demonstrating MU for each EP. Group measure information or measure information specific to another practitioner is NOT ACCEPTABLE in attesting to MU. 5. In meeting MU standards and thresholds, do I have two years of each Stage, or does it vary based on my participation? CMS has recently clarified that providers will be allowed two years of each stage of MU even if not participating in consecutive years. EPs participating in the Medicaid EHR incentive program are not required to participate in consecutive years and there is no Medicaid financial penalty for skipping a year. EPs have the option of starting and stopping the program based on their meaningful use readiness. For example: 19

20 2011 met AIU requirements 2012 met 90 days of Stage 1 meaningful use requirements 2013 did not participate 2014 did not participate 2015 met 365 days of Stage 1 meaningful use requirements 2016 met 365 days of Stage 2 meaningful use requirements 2017 did not participate 2018 met 365 days of Stage 2 meaningful use requirements 2019 and thereafter progress to Stage 3 requirements 6. What are the general requirements for MU? Eligible professionals must meet patient volume requirements, have certified EHR technology (CEHRT), meet the core and menu measures, submit the required number of clinical quality measures (CQMs), and meet the following general MU requirements: a. 50% of all encounters must occur in locations equipped with CEHRT. i. To demonstrate that a provider meets this requirement, encounters across all practice locations (excluding inpatient and emergency room settings) must be reported. ii. An encounter is defined as medical, diagnostic, or consultation services. If multiple services are provided on the same day to the patient, then it counts as one encounter. b. 80% of unique patients seen at locations with CEHRT must have their records in a certified EHR system Providers should note that MU is not limited to just Medicaid encounters and patients but is reflective of all encounters and patients. For detailed information on each core and menu measure, visit Guidance/Legislation/EHRIncentivePrograms/Downloads/EP-MU-TOC.PDF. 7. What if I change systems during the EHR reporting period? If a provider changes EHR systems or practices at multiple practices, information from all systems utilized during the reporting period must be used. CHANGING SYSTEMS: If the information from the old system is transitioned into the new system, and the new system can report data from the entire reporting period, then only report data and include documentation from the new system. If the data is not transferred, then the information from both systems should be combined and documentation from both systems uploaded. MULTIPLE LOCATIONS: Information from each location for the reporting period must be uploaded. The numerators and denominators for each measure should be combined and entered into the application. If a provider is practicing at multiple practices utilizing different systems, and different menu and clinical quality measures (CQMs) have been selected at the varying locations, the provider should choose one set to report. All core measures must be added together. Any menu and CQMs that are the same for all practices should also be added together. Providers should upload reports for all measures from both systems as well as a document explaining which menu and CQMs they are choosing to report. Documentation should be maintained supporting the choice of measures. For more information on practicing at multiple locations, please see this Fact Sheet published by CMS. 8. As an Eligible Professional, what documentation should be provided with my MU attestation? Report from your practice management system (PMS) or billing system supporting your volume 20

21 Meaningful use Measure report from your certified EHR including core, menu, and clinical quality numerical measures The completed Additional Documentation (AD) Form o It is acceptable to provide this level of information in another format such as reports from your EHR, but all information must be provided. For Menu Measure #9 Immunization Registry: A copy of your documentation from Florida SHOTS if not excluding because you did not provide any immunizations during the EHR reporting period NOTE: Refer to Part 2: Eligibility: Eligible Professionals for additional documentation that may be required for certain provider types. 9. What should I do if there are no Clinical Quality Measures (CQMs) that apply to my practice? EPs are required to report on these measures even if the numerator and denominators are zeroes. CQMs you can report on may be determined by your vendor s 2014 certification. For more information on CQMs, refer to Clinical Quality Measures. Providers should be aware that CQM requirements changed for the 2014 program year. EPs are required to report on nine out of 64 CQMs that cover at least three of the six quality domains. 10. How will the online application handle percentages? For example, the MU Measure report states 29.8% for a measure will the system round that up to 30%? The online state application (MAPIR) only rounds down to the whole number. In this example, MAPIR would calculate that as 29%. Additionally, providers should be cautioned that the rule requires that measures be met at more than the specified threshold. So in this example, if the measure requires more than 30%, your percentage must be at least to meet the measure. MAPIR will display the percentage at 30% but will pass the measure. If your percentage is 29.8%, MAPIR will display 29% and the measure will fail. 11. What is the purpose of the Additional Documentation Form (AD Form)? The AD Form provides information to support the data entered into the attestation/application for pre-payment validation and post-payment review activities. One important function is the capturing of location specific information supporting the provider s attestation to meeting general requirements (referenced in Question 6 of this section). It should be noted that additional documentation may still be requested to support oversight activities. In Section A of the form, information about each location at which the provider practices should be included with the exception of inpatient and emergency room settings. Section B auto calculates based on the information in Section A. NOTE: If a provider practices at various locations but all locations utilize the same technology and all patients are included in the certified technology, Section A does not need to be completed. Section C provides for details on certain core and menu measures and is required as part of the application process. If any of the questions are not applicable, please indicate N/A. If a provider is practicing at multiple locations with EHR technology, it may be necessary to complete Section C for each of those locations since the answers may vary dependent on the location. EPs should use the AD form that is specific to your MU stage. Click here for AD Forms. 12. What are the payment adjustments for not meeting MU? Those providers that are eligible for the Medicare Incentive Program but have not successfully attested to MU can be subject to an adjustment on their Medicare payments. The payment adjustments only apply to Medicare not to Medicaid. A provider can, however, can report MU under the Medicaid incentive program and avoid the Medicare payment adjustments. 21

22 Providers can avoid the payment adjustment by applying for a hardship exemption through CMS. For the most up to date information, please refer to Payment Adjustments and Hardship Exemptions. 13. Can I still exclude menu measures? Regardless of MU stage, providers will no longer be able to claim exclusions and have the exclusion(s) count towards meeting the minimum number of required menu measures. If providers claim an exclusion(s) and cannot pass the minimum required number of menu measures - then all menu measure measures must be answered to ensure that there are no other measures they can meet. There are two ways providers can pass menu measures: Pass the minimum required menu measures without taking any exclusions. This means being able to attest accurately Yes to measures with Yes or No for the answer and meet thresholds for all other menu measures. Pass fewer than the required minimum number and meet the exclusion for the rest of the menu measures. 14. What is required for reporting Clinical Quality Measures (CQMs)? Regardless of MU stage, providers will be required to report on 9 out of 64 clinical quality measures. These 9 measures must cross at least three of the 6 quality reporting domains. Providers will not have to meet a threshold for any of the 9 reported measures. To facilitate provider reporting, CMS has a recommended set of Adult CQMs and Child CQMs. These are: Adult Controlling High Blood Pressure Use of High Risk Medications in the Elderly Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention Use of Imaging Studies for Low Back Pain Preventive Care and Screening: Screening for Clinical Depression and Follow-Up Plan Documentation of Current Medications in the Medical Record Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Closing the referral loop: receipt of specialist report Functional status assessment for complex chronic conditions Child Appropriate Testing for Children with Pharyngitis Weight Assessment and Counseling for Nutrition and Physical Activity for Children and Adolescents Chlamydia Screening for Women Use of Appropriate Medications for Asthma Childhood Immunization Status Appropriate Treatment for Children with Upper Respiratory Infection (URI) ADHD: Follow-Up Care for Children Prescribed Attention-Deficit/Hyperactivity Disorder (ADHD) Medication Preventive Care and Screening: Screening for Clinical Depression and Follow-Up Children who have dental decay or cavities 15. What are the six quality domains for CQMs? Patient and Family Engagement Patient Safety Care Coordination Population and Public Health Efficient Use of Healthcare Resources Clinical Processes/Effectiveness 22

23 16. For the measure of providing educational resources, is it required that my EHR actually generate the materials? It is not required that the certified technology actually generate the educational material but it is required that material be suggested by the CEHRT based on the information within the system. Certified electronic health records use the patient s problem list, medication list or laboratory results to identify clinically relevant education resources for a specific patient. Additional information within the record may also be used. The provider can make the final decision on whether the education resource is useful and relevant on a per patient basis. Audits have found that although providers may have a MU report showing that the measure is met, they are unable to demonstrate that their system actually suggested educational resources. Providers are encouraged to work with their vendor to understand how the system generates educational resource suggestions, how the MU report is generated, and what documentation is available to support meeting this requirement. 17. For Stage 1, what is recommended to prove compliance with Core Measure 15 Privacy and Security Assessment? Updated It is the responsibility of the provider to determine if they have met the requirements of 45 CFR (a) (1) and correctly identified security deficiencies as part of its risk management process. The Agency requests that you provide the identification of the person completing the assessment and the date completed on the Additional Documentation (AD) Form. The assessment could have occurred prior to the beginning of the reporting period; however, a new review will have to be conducted for each subsequent reporting period. For example, a Security Risk Assessment was completed September This counts for the 2013 program year. The Security Risk Assessment was reviewed and updated September This counts for the 2014 program year. The September 2013 Security Risk Assessment cannot be used for the 2014 program year applications. The complete assessment, including any backup documentation, should be maintained by the provider. The assessment must be completed and identified deficiencies corrected or a plan of correction in progress no earlier than the start of the EHR reporting year and no later than the provider attestation date. For example, a EP who is reporting MU for a 90-day EHR reporting period, may complete the appropriate security risk analysis requirements outside of this 90-day period as long as it is completed no earlier than January 1st of the EHR reporting year, and no later than the date the provider submits their attestation for that EHR reporting period. A new review will have to be conducted for each subsequent reporting period. For example, a Security Risk Assessment was completed September This counts for the 2013 program year. The Security Risk Assessment was reviewed and updated February 2015 for program year The February 2015 Security Risk Assessment cannot be used for the 2015 program year applications. A new review is required. STAGE 2 SPECIFIC 1. What are the Stage 2 requirements? In that each stage of MU builds upon the previous, the focus of Stage 2 is increased patient engagement and exchange of information. The number of measures and complexity of measures is increased as well as the percentage thresholds that must be met. Below is a synopsis of Stage 2 requirements. For complete information, visit: CMS Stage 2 Specification Sheets. Two general requirements o 50% of encounters at locations with certified technology o 80% of unique patients seen during the EHR reporting period must have their information in CEHRT 17 core measures 23

24 3 out of 6 menu measures 9 clinical quality measures (must select 3 of the 6 national quality strategy domains) 2. How do providers determine whether that Stage 2 requirements are met? Providers should work with their vendor for an understanding of how their particular system captures and reports Stage 2 measures. Many of the measures have multiple components that must be met and require exchange with other systems. Workflow and staff roles may need to be adjusted to ensure that information is being entered into the system in such a way that the necessary information is being captured. Running your meaningful use report early and often will gauge and track your progress. 3. Will there still be exclusions to Stage 2 measures? Yes. For some of the core measures there is an exclusion that can be taken. Effective in 2014, for menu measures, providers will no longer be able to claim exclusions and have the exclusion(s) count towards the minimum number of required menu measures. If a provider claims a menu measure exclusion, they will have to answer all remaining menu measures to ensure that there are no other measures they can meet. 4. For the Stage 2 CPOE measure, what is meant by credentialed medical assistant? Are there minimal requirements that must be met? This measure does not set standards for credentialing or certifying medical assistants rather the intent is to expand and specify the scope of the individuals that can be recognized in meeting the measure. Florida law specifies that (Florida Statutes ) medical assistants may be certified by the American Association of Medical Assistants or as a registered medical assistant by the American Medical Technologists. It is the responsibility of the provider attesting to the measure that if a credentialed Medical assistant is used to enter CPOE for the purpose of this measure, documentation of the requisite credentialing is obtained and maintained and that state, local and professional guidelines are being met. Please note that CMS (FAQ7709) states that the credentialing cannot come from the employing organization. Additionally CMS (FAQ9058) specifies that anyone within the practice, regardless of job title that has received medical assistant credentialing can enter orders and be included in this measure. 5. How can I determine whether I qualify for an exclusion due to lack of broadband availability? For certain Stage 2 Measures, EPs can claim an exemption if the EP conducts 50 percent or more of his or her patient encounters in a county that does not have 50%or more of its housing units with 3Mbps broadband availability according to the latest information from the Federal Communications Commission (FCC) on the first day of the EHR reporting period. Based on the research conducted by staff at the Agency for Health Care Administration (AHCA), it does not appear that any Florida county meets the exclusion requirement. The link and the instructions are below if you are interested in how the determination was made that no Florida county meets the exclusion requirement: 1. Go to 2. Click on Analyze the Data 3. Click on Rank a. Under Rank within the Nation, Click "STATE", then under Rank within a State click COUNTY b. On "Select State", Click on your state from the drop down list c. Click Select Metric" - SPEED d. Click "Generate the list". The default data listed is for population. To obtain data for households as specified in the regulations: Click "Manage Metrics" 4. On the line that states "Select the baseline metric", click "HOUSING UNITS" 5. Click "GENERATE THE LIST" 24

25 Part 7: PARTICIPATION PENALTIES 1. Will I be penalized for not participating in the Medicaid Electronic Health Record (EHR) Incentive Program? No, participation is voluntary. Medicaid reimbursements will not be affected if you choose not to participate. 2. Will I be penalized for not participating in the Medicare EHR incentive program? Eligible professionals (EPs) may participate in either the Medicaid or Medicare incentive programs and must demonstrate meaningful use (MU) prior to 2015 in order to avoid a reduction in Medicare reimbursement. For detailed information on how the penalty will be determined and applied, visit Medicare Payment Adjustments. MEDICARE VS. MEDICAID INCENTIVE PROGRAMS 1. Can I switch between the Medicare and Medicaid incentive programs? Yes, but you are limited to one change and it must be for a payment year before The switch is only counted if it occurs after an initial payment from either program. If you are SWITCHING from participating in the Medicare Program to the Medicaid Incentive Program, you must attest to the full calendar year of MU for your initial Medicaid program payment. Once a provider has attested to 90 days of MU (as was required for the initial Medicare payment), the next required reporting period will be 365 days, regardless of the program in which you are participating. The only exception is for Program Year 2014, during which time all providers, regardless of stage, will only be required to have a 90-day reporting period. The total amount of payments you could receive from a combination of programs will not exceed the Medicaid program maximum amount of $63, Can I receive both the Medicare and Medicaid EHR incentive payment? No. EPs may not receive payments from both Medicare and Medicaid at the same time. Eligible hospitals may participate in both Medicaid and Medicare. 3. Where can I find out more information about the Medicare Incentive Program? For more information about the Medicare Incentive Program, visit CMS EHR Incentive Programs. 25

26 Part 8: FEDERAL REGISTRATION and STATE APPLICATION PROCESS 1. Can I register as a group? No. Each individual eligible professional (EP) must complete the application and attestation process. A group administrator or other designated proxy may complete the application process on behalf of the EP. Refer to Part One for additional information. 2. What should be done if a provider has an active Florida Medicaid Provider number but cannot access the State application? Before you can apply for a Florida Medicaid Electronic Health Record (EHR) Incentive Payment, you have to complete the registration process at the Centers for Medicare and Medicaid Services (CMS) EHR Registration and Attestation site (R&A). If the information from the R&A matches the information contained in your Florida Medicaid provider file, then you should receive an directing you to the state application (MAPIR) link. If you don t receive an (check your junk mail) from the state s registry, [email protected], within 3 days of completing your registration you may call the EHR Contact Center toll-free at for further information. 3. Where is the link to the State Application? The link to the state application is on your Medicaid provider portal. Upon signing into the Medicaid provider portal, a link should be present in the top, right hand corner under Quick Links. Clicking on the EHR Incentive Payment link will take you to the Medicaid EHR Incentive Program Participation Dashboard. The Dashboard displays information on any previous Florida Medicaid application and any program year application that is available for completion. If you have successfully registered with the R&A, and your information matches the Medicaid s provider file (National Provider Identification (NPI) and Tax Identification Number (TIN)), your application status will say Not Started. If your R&A registration did not match your provider file, you will see an error message Not Registered at R&A. If you have not registered with the R&A, you will see an error message Not Registered at R&A. If you do not have a Medicaid provider portal sign on, or cannot remember your sign on credentials, contact , option 5. Please wait 3 days after registering with CMS at the R&A site before trying to access your state application. If you receive the Not Registered at R&A status, please contact the EHR Call Center at 1 (855) for further assistance. 4. I have registered with the CMS Registration and Attestation (R&A) but cannot access the state application. What should I do? If the state application link is not present, please contact the EHR Call Center at 1(855) for further assistance. If the R&A registration information does not match your Florida Medicaid provider file, you are placed on a mismatch report. You will not be able to complete your state application until the matching issue is resolved. Common reasons for mismatching are: You are not an eligible provider type. Eligible provider types are: MDs and DOs; Dentists; Nurse Practitioners; and Physician Assistants (PA) working in PA-led federal qualified health centers (FQHCs) and rural health clinics; 26

27 Your Florida Medicaid enrollment is inactive; The applicant s NPI entered as part of the federal registration process is not contained in your Florida Medicaid provider file; You are not a fully enrolled Medicaid provider (this would apply to those providers that mainly participate in Managed Care programs; There is a typographical error in the applicant s NPI or Social Security Number (SSN); The applicant s SSN is not in your Florida Medicaid provider file; or The payee s NPI and/or TIN received from the R&A conflicts with the information in the Florida Medicaid system. Please contact the EHR Call Center at (855) for assistance in resolving mismatch issues. If you are not an eligible provider type for the Medicaid incentives but qualify for the Medicare Incentive Program, you can change your registration at the federal level selecting the Medicare program. If you do not qualify for the Medicare program, then you should cancel your registration. 5. Can I change the information at the federal registration and attestation site (CMS R&A)? Yes, in fact certain changes must occur at the federal CMS R&A system, such as switching between the Medicare and Medicaid program, payee changes, and state participation. It is important to note that when making a change at the R&A site, you must hit the resubmit button. Even if you do not make a change to the information, you must hit resubmit. If you do not resubmit, your R&A information is considered pending and will affect your ability to complete an application and receive a payment. 27

28 Part 9: PAYMENTS 1. How long will it take to receive my Electronic Health Record (EHR) Incentive payment? Once your EHR incentive payment application is successfully submitted through MAPIR (the online state application) and all attestations and documentation are approved, your payment should be processed within 30 business days. You will receive s from Florida Medicaid to confirm your registration has been submitted, to notify you that the payment was approved, and to notify you the payment has been processed. The pre-payment review may take more than 30 days depending on the number of applications that have been submitted. Applications are reviewed in the order in which they were submitted. 2. Can I receive more than one incentive payment each year? Only one incentive payment is allowed each program year. It is possible for an Eligible Professional (EP) to receive payments within the same calendar year. if they are applying for their adopt, implement, upgrade (AIU) payment during a grace period, and then apply for their second year payment for 90-days of meaningful use (MU) for the same calendar year, or if they are applying in 2014 in which case all providers have a 90-day reporting period. 3. How much are the incentive payments? Medicaid EPs can receive $63,750 over six years. The first year payment is $21,250 with subsequent year payments being $8,500. Payments are paid in lump sum amounts. Pediatricians qualifying with a 20% Medicaid patient volume will receive two-thirds of the maximum incentive payment, or $42,500. Eligible hospital (EH) payments are paid out in installments over a three-year period. There is not a reduction in payment if an EP does not participate in consecutive years. 4. Can I assign my payment? EPs can decide to receive the payment or assign it to a group with which they have an employment or contractual relationship that allows the group to apply and receive payment for their covered services. The payment assignment relationship must be established in the Florida Medicaid Managed Information System (FLMMIS) prior to attestation. In addition, the EP must be a member of the group at the time of every attestation. When an application is returned to incomplete status for corrections, resubmission requires a new attestation. If a provider left a group after the initial attestation and the application needs no corrections that require a new attestation, the group can receive the payment. If a provider leaves a group after attestation and the application is returned to Incomplete for corrections, the provider cannot assign the payment to the group. Each new attestation requires attesting to all the information in the application including the payment assignment. Payment assignment is made as part of the federal registration and attestation process (R&A). Any reassignment of the payment is made voluntarily, which assumes informed consent has been given by the EP. This means that the EP understands that the party so designated, not the EP, will receive the payment. There are three options for payment assignment at the CMS R&A. It is important to pick the correct option or payments will be delayed. The data for the individual provider and the payee must match Medicaid provider files. o Social Security Number (SSN): This option uses the provider s individual National Provider Identification (NPI) and SSN for the payment o My Billing Tax Identification Number (TIN): This option uses the provider s individual NPI and allows entry of a TIN o Group re-assignment: This option allows the provider to enter a group NPI and Tax ID The system validates that the NPI/TIN combination is on file with PECOS. 28

29 It is strongly recommended that practices discuss the EHR payment with EPs prior to attesting. It is also recommended, but not required, that groups execute a signed agreement outlining the payment relationship prior to attesting. If the State is notified that an EP did not agree to have the payment assigned to the group who received it, then recoupment action will be taken. 5. How is payment assignment validated? As part of the pre-payment validation process, the State will verify that the EP is a member of the group to whom payment has been assigned based on the information contained in FMMIS. If that relationship has not been established in FMMIS, the payment will not be approved. If it is found that the EP was not truly a member of the group at the time of attestation (e.g. left and FMMIS not updated), then payment will be recouped. 6. Where is the payment directed? The registration with the CMS R&A establishes the NPI and Tax ID for the payment. MAPIR will display the Medicaid IDs associated with that NPI/TIN combination in the on line application. The EP selects the Medicaid ID for the payment. If MAPIR does not display the Medicaid ID you were expecting to see, it is necessary to update the registration. A common registration error is selecting the payee TIN option of My Billing TIN. This option pre-populates the individual provider s NPI and allows entry of the group EIN. Once a payee Medicaid ID is selected and the application is approved, the payment is made as part of the normal financial cycle and can be found on the remittance advice under non-specified claim payments with a disposition code of Payments are made based on the existing information contained in FMMIS including EFT information. If you plan on receiving the payment yourself, please contact the EHR Call Center to verify that your Medicaid file contains your correct address and electronic funds transfer (EFT) information. The EHR Call Center number is Is the incentive payment subject to federal income tax? Incentive payments should be treated like any other income and are subject to Federal and State laws regarding income tax, wage garnishment, and debt recoupment. Providers should consult with a tax advisor or the Internal Revenue Service regarding how to properly report this income on their filings. The incentive payment will be included in 1099 reporting. 8. Can organizations request payments on behalf of their EPs, including attesting to required information? EPs must legally attest that they meet the requirements in order to receive payments. Organizations are not allowed to apply for incentive payments without the knowledge and consent of their employees. 9. What should be done if a notification that payment is being processed has been received, but it has been more than 30 days and I have not received it? If you have received an stating that you could expect your incentive payment within 30 days but you have not received your payment, then contact the EHR Call Center at (855) Providers should not log into their federal registration at the R&A as this causes the registration to be considered updated and can cause additional delays. 10. I have completed my application but have not received notification of payment? If you submitted your application in MAPIR more than 30 days ago and have not received any type of update or communication from EHR processing staff, please contact the EHR Call Center at (855) Providers should not log into their federal registration at the R&A as this causes the registration to be considered updated and can cause additional delays. 29

30 Part 10: PUBLIC HEALTH REPORTABLE LAB RESULTS FOR ELIGIBLE HOSPITALS AND CRITICAL ACCESS HOSPITALS 1. Will Florida be accepting data in meaningful use (MU) Stage 1 to meet the reportable lab results public health reporting menu option for eligible hospitals and critical access hospitals? Yes. Florida Department of Health (DOH) will be accepting data from eligible hospitals (EHs) and critical access hospitals to meet the reportable lab results menu option. The DOH has a statewide system for accepting reportable lab results. For more information contact: [email protected] 2. Where can I register my intent to submit reportable lab results data to DOH? The Registration of Intent for reportable lab results can be found by clicking here. SYNDROMIC SURVEILLANCE REPORTING 1. Will Florida be accepting data to meet the syndromic surveillance public health reporting menu option for EHs and critical access hospitals? Yes. FDOH is accepting data to meet the syndromic surveillance menu option for both MU Stage 1 and Stage 2. The Electronic Surveillance System for the Early Notification of Community Epidemics (ESSENCE) is Florida s statewide syndromic surveillance system and is the public health registry that will receive syndromic surveillance data. 2. Will Florida be accepting data to meet the syndromic surveillance public health reporting menu option from Eligible professionals (EPs)? No. At this time Florida is accepting data only from eligible hospitals, critical access hospitals, and urgent care centers. Further questions can be directed to [email protected] 3. Where can I register my intent to submit syndromic surveillance data to DOH? The Registration of Intent for syndromic surveillance reporting can be found by clicking here. 4. For Stage 1, can an EP choose the Syndromic Surveillance Reporting Public Health Measure? EPs are discouraged from choosing this measure because there is no syndromic surveillance reporting registry for physicians in Florida. If you are a provider that gives no immunizations, you can still choose that measure and claim an exclusion. If you are a provider who gives immunizations of any kind, you must test with Florida SHOTS. 5. I am not a pediatrician and only give a few flu shots each year. Can I exclude from the Syndromic Surveillance measure? If you provide any immunizations, you must register with Florida SHOTS and work toward electronic submission. Immunizations include flu, hepatitis, tetanus, HPV, pneumococcal and other immunizations. Effective for the 2014 program year, exclusions no longer count toward meeting a menu measure. If you exclude from the Syndromic Surveillance, you must also answer the Immunization measure. If you did not provide any flu shots or other immunizations during your 90-day reporting period, you can exclude from the immunization measure. 30

31 IMMUNIZATIONS (Eligible Hospitals, Critical Access Hospitals, and Eligible Professionals) 1. What is the process for electronically submitting immunization data to Florida SHOTS? Florida SHOTS is the immunization reporting registry for Florida and has established a process by which providers, including hospitals, can satisfy meaningful use requirements. The first step is to complete a registration form. Complete information on the process can be found by clicking here.. Registration for Stage 2 will be linked to your FLShots.com logon. If you are not participating in Florida SHOTS, you will need to contact Florida SHOTS to establish an account. Please use this website to enroll if you do not have a Florida Shots log in. Providers, including hospitals, are encouraged to fully and accurately complete the registration with as much information as possible to expedite processing. A couple of key points: The contact name and will be used for all subsequent correspondence. The form is dynamic, meaning that depending on the answers given, additional questions may appear. Use Internet Explorer as your web browser when accessing Florida SHOTS. Other browsers will not allow the site to operate properly. Stage 1 registrants can expect to receive testing instructions within three business days. Stage 2 registrants will be sent instructions to contact an implementation specialist if they are not already uploading. Stage 2 registrants who are already uploading will be provided confirmation documentation after their designated reporting period. It is the provider s responsibility to complete the testing process in order to receive documentation indicating testing outcome. The documentation should be received within ten business days of completing the testing process. The testing outcome documentation must be included with the application. EXCLUSIONS: If a provider does not give any type of immunizations OR has not provided any immunizations within the EHR reporting period, an exclusion may be claimed. It is not necessary to register with Florida SHOTS if excluding from this measure because no immunizations were provided. ONGOING SUBMISSIONS: Documentation supporting ongoing submissions can also be obtained through the link above. In completing the registration, please verify that your Florida SHOTS Organization Login ID is accurate. This is how the system will be able to confirm the batch process. Questions about testing with Florida SHOTS or the Immunization Registry should be directed to Florida SHOTS by at [email protected] Providers are encouraged to start the process of testing with Florida SHOTS prior to or early in the EHR reporting period. NOTE: Manually entering data into the Florida SHOTS web portal or a fixed file transfer does not meet meaningful use requirements it must be an electronic exchange of information. 2. What is the Stage 1 immunization measure? Updated The provider must have performed at least one test of certified EHR technology s capacity to submit electronic data to immunization registries and follow-up submission if the test is successful. If a provider has achieved ongoing submission with Florida SHOTS prior to or during their EHR reporting period, then they are not required to perform a test but will need documentation of ongoing submission during their EHR reporting period. A letter documenting submission during a prior reporting period is not acceptable. 31

32 Providers attesting to their second year of Stage 1 measures must perform a test unless they have achieved ongoing submission or have documentation from Florida SHOTS advising not to perform the test. Providers must upload documentation from Florida SHOTS of either their status at the end of the EHR reporting period or the documentation from Florida SHOTS advising not to perform the test. Click here for more information. 3. What is the Stage 2 immunization measure? Successful ongoing submission of electronic immunization data from certified EHR technology (CEHRT) to an immunization registry or immunization information system for the entire EHR reporting period as defined: a. Ongoing submission achieved and continued throughout EHR reporting period. Ongoing submission was already achieved for an EHR reporting period in a prior year and continues throughout the current EHR reporting period using either the current standard at 45 CFR (f)(1) and (f)(2) or the standards included in the 2011 Edition EHR certification Immunization Registries Data Submission criteria adopted by the Office of the National Coordinator for Health (ONC) during the prior EHR reporting period when ongoing submission was achieved. b. Registration by deadline and ongoing submission achieved. Registration with the Public Health Agency or other body to whom the information is being submitted of intent to initiate ongoing submission was made by the deadline and ongoing submission was achieved. c. Registration by deadline and testing during EHR reporting period but ongoing submission not achieved. Registration of intent to initiate ongoing submission was made by the deadline and the EP or hospital is still engaged in testing and validation of ongoing electronic submission. d. Registration by deadline but Florida SHOTS not ready for testing by the end of the EHR reporting period. This is not an option for Florida providers as Florida SHOTS has no waiting list for testing and validation. It should also be noted that criterion does not apply to situations where a provider has registered with Florida SHOTS by the deadline but has not been able to test because of issues with their EHR vendor s readiness. Providers who have not achieved ongoing submission prior to their EHR reporting period must register with Florida SHOTS by the deadline and respond to any request from Florida SHOTS within 30 days. Providers will fail the Stage 2 Immunization measure if they have two instances of not responding to a request within 30 days. 4. What documentation is required for Stage 2 Immunizations? Florida SHOTS has information on their website about the procedures providers must follow to satisfy Stage 2 requirements. Documentation must be specific to the program year to which the provider is attesting and must come from FL SHOTS. 5. For Stage 2, what is the deadline to register with Florida SHOTS? Providers attesting to Stage 2 must follow the requirements for Stage 2 that include registering with Florida SHOTS by the deadline of no later than 60 days after the start of their EHR reporting period and working with Florida SHOTS toward ongoing submission if it was not already achieved. Providers must upload documentation from Florida SHOTS regarding their status at during and at the end of the EHR reporting period. Key points are: a. Registration with Florida SHOTS for Stage 2 requires the healthcare provider personnel who are designated Florida SHOTS Local Org Administrators to register for Meaningful Use Stage 2 within the Florida SHOTS registry by logging into the registry. The online form can be found here. b. The date of the end of the EHR reporting period must be completed. 32

33 c. The Florida SHOTS registration system for Stage 2 will not allow for entry of an EHR reporting period end date in the past. d. Providers who achieved ongoing submission prior to their 2014 EHR reporting period and did not register by the deadline, must register and enter a date the form will accept. Providers should follow up with Florida SHOTS to provide the accurate end date for their EHR reporting period. Registration for Stage 2 will be from your FLShots.com logon. If you are not participating in Florida Shots, you will need to contact Florida Shots to establish an account. The is [email protected]. 6. Can a failed test with Florida Shots meet the requirements for Stage 2 for Immunization Reporting? No. For Stage 2, the measure statement is: successful ongoing submission of electronic immunization data from CEHRT to an immunization registry or immunization information system for the entire EHR reporting period. 7. How long will it take to get the documentation necessary from Florida Shots for my application? Stage 1 documentation is provided at the end of the testing period. For Stage 2, the measure requires providers to attest to activities that occurred during and throughout the EHR reporting period. The provider s status regarding ongoing submission is not known until the end of their EHR reporting period. Florida SHOTS will provide documentation of the status within 10 days after the end of the reporting period. 8. Where can more information be found about immunization reporting? For information regarding Florida SHOTS, click here or by at [email protected] CANCER REGISTRY AND SPECIALIZED REGISTRY REPORTING 1. Is there a Cancer Registry for reporting cancer cases to satisfy the Stage 2 menu measure? The Florida Cancer Data System (FCDS) is Florida s Cancer Registry. The FCDS is a joint project of the Florida Department of Health and the University Of Miami Miller School Of Medicine. FCDS is accepting electronic submission of cancer data. Please visit their website at to register for electronic submission of cancer data. 2. Does Florida Department of Health (DOH) have any specialized registries? The Florida DOH has no specialized registries capable of receiving electronic submission of data. This Stage 2 menu measure has four possible exclusions: a. The EP does not diagnose or directly treat any disease associated with a specialized registry sponsored by a national specialty society for which the EP is eligible, or the public health agencies in their jurisdiction; o e.g. the provider does not treat associated diseases b. The EP operates in a jurisdiction for which no specialized registry sponsored by a public health agency or by a national specialty society for which the EP is eligible is capable of receiving electronic specific case information in the specific standards required by CEHRT at the beginning of their EHR reporting period; o e.g. there is a registry but it does not accept electronic reporting 33

34 c. The EP operates in a jurisdiction where no public health agency or national specialty society for which the EP is eligible provides information timely on capability to receive information into their specialized registries; or o e.g. there may or may not be a registry but a provider cannot obtain information on enrolling d. The EP operates in a jurisdiction for which no specialized registry sponsored by a public health agency or by a national specialty society for which the EP is eligible that is capable of receiving electronic specific case information in the specific standards required by CEHRT at the beginning of their EHR reporting period can enroll additional EPs. o e.g. there is a registry capable of receiving electronic data but there is a waiting list The Centers for Medicare and Medicaid Services (CMS) has stated that if there is not a specialized registry within the provider s public health jurisdiction that accepts reporting then an exclusion can be claimed. It is not required that the provider seek beyond their public health jurisdiction for a registry unless a national specialty society registry is readily known. 3. What documentation is required to claim an exclusion for specialized registries? Providers who claim an exclusion will be required to complete the Additional Documentation form with information on why they are excluding. 34

35 Part 11: CERTIFICATION FLEXIBILITY RULE 1. How does the Certification Flexibility Rule affect my participation in the Program? The Certification Flexibility Rule, effective October 1, 2014, allows providers options when attesting for Program Year 2014 if they have been unable to fully implement 2014 certified electronic health record technology (CEHRT). Options are: Demonstrate 2013 Definition of Stage 1 of MU with 2011 Edition CEHRT or a combination of 2011 and 2014 Edition CEHRT; OR Demonstrate 2014 Definition of Stage 1 of MU with 2014 Edition CEHRT or a combination of 2011 and 2013 Edition CEHRT; OR Demonstrate Stage 2 of MU with 2014 Edition CEHRT The required CQMs are tied to the Stage of MU being reported. The rule operationalizes the term unable to fully implement as: Software development delays Missing or delayed software updates Unable to implement 2014 CEHRT for the full reporting period Unable to train staff, test the updated system, or put new work flows in place because of delays associated with installation of 2014 CEHRT Unable to meet Stage 2 summary of care measures because the recipient of transmittals was impacted by 2014 CEHRT issues Reasons that do not count as delays in 2014 Edition CEHRT: Financial issues Inability to meet one or more measures Staff turnover and changes Provider waited too long to engage a vendor Refusal to purchase the requisite software updates Providers who fully implemented 2014 Edition CEHRT and can report in How will providers know their options for the 2014 program year? The options available to providers depend on the certified product in use during the reporting period and if the product was not certified to the 2014 edition, the reason for the delay. The following examples assume the provider/practice meets the requirements for being unable to fully implement 2014 edition CEHRT in time to have a 90 day reporting period: If the practice was using 2011 edition CEHRT during the reporting period, the certification number should start with a letter and have several zeros then a combination of numbers and letters; e.g., A000001CFES9EAB. The provider will attest to 2013 measures. If the practice was using a combination of 2011 CEHRT and 2014 CEHRT during the reporting period, the certification number will have H13 as the third through fifth digit; e.g.,a0h1301cfes9eab. The provider has the option of attesting to 2013 or 2014 measures. Providers scheduled to attest to Stage 2 measures will have three options: 2013 Stage 1, 2014 Stage 1, or 2014 Stage 2 measures. If the practice was using 2014 edition CEHRT during the reporting period, the certification number will have 14E as the third through fifth digits; e.g., 1314E01CFES9EAB. The provider will attest to

36 measures. Providers scheduled to attest to Stage 2 measures can attest to Stage 1 measures if they are unable to meet the Transition of Care measure because the providers they refer to were unable to fully implement 2014 edition CEHRT due to delays in 2014 CEHRT availability. 3. What are the situations where a provider can use a combination certification number? There are three situations for which a provider can use a combination certification number. All situations involve the provider using 2011 edition CEHRT for part of the EHR reporting period and 2014 edition CEHRT for the rest of the reporting period. Providers who used 2011 or 2014 edition CEHRT for the entire reporting period must obtain a certification number that reflects their certified edition. Use of a combination CEHRT number includes: Providers who began their EHR reporting period with 2011 edition CEHRT and upgraded to 2014 edition CEHRT before the end of the reporting period. Providers who have a modular system. During the EHR reporting period some components had 2011 certification and some had 2014 certification. The practice has more than one location and the providers rotate among the locations. During the EHR reporting period, the practice began a staggered deployment of the 2014 edition CEHRT. The providers began the reporting period with all locations using 2011 edition CEHRT. 4. How are Clinical Quality Measures (CQMs) affected by the Certification Flexibility Rule? Program year 2013 has a different set of CQMs from program year Providers must report on the CQMs that correspond to what program year Core and Menu measures they are reporting. If you are reporting program year 2013 Core and Menu measures, you report program year 2013 CQMs. If you are reporting program year 2014 Stage 1 or Stage 2 Core and Menu measures, you report program year 2014 CQMs. For the 2014 program year only, providers are allowed to use a different reporting period for CQMs than for Core and Menu measures. Providers who are attesting to a different reporting period for CQMs than for Core and Menu measures must upload documentation explaining the reason for the different reporting periods. The documentation does not have to be a letter from the vendor. 5. What CQMS do I report if I am using a combination of 2011 and 2014 CEHRT? The Centers for Medicare and Medicaid Services (CMS) is allowing providers who are attesting to the 2013 Stage 1 objectives and measures using a combination of 2011 Edition and 2014 Edition certified electronic health record technology (CEHRT) to use a subset of data for CQMs for any period of time in which the 2011 Edition CEHRT was in place. Example: A provider was unable to fully implement 2014 edition CEHRT to have a full 90-day reporting period for the 2014 program year. The provider uses 2011 edition CEHRT for the first 60 days of their reporting period and then uses 2014 edition CEHRT for the remaining 30 days of their reporting period. The provider chooses to attest to the 2013 Stage 1 Core and Menu measures. In this situation, the provider may report on 2013 CQMs for that 60-day period. See section 79 FR of the rule for more information. Providers are encouraged to discuss with their vendor whether the 2014 edition CEHRT will be capable of calculating 2013 CQMs. The capability of the system may dictate what options are available to providers. 36

37 6. What do providers need to do to attest based on one of the options under the Certification Flexibility Rule? The Agency has developed a supplemental attestation document for providers to complete indicating the reason for exercising an attestation option. This supplemental documentation will be required to be uploaded as part of the online application. Providers/practices should provide complete details on the reason they were unable to fully implement 2014 edition CEHRT in time to have a 90 day reporting period for the 2014 program year. The Certification Flexibility Attestation form is posted to the EHR Program website. MAPIR will be ready for attestations under the Certification Flexibility Rule in the spring of Providers must wait to start applications until the system changes are installed. Applications started before the system changes are installed will need to be aborted to attest to a flexibility option. 7. What is the effective date for Stage 3 meaningful use? The Certification Flexibility Rule specified that Stage 3 MU will not begin until FY 2017 for EHs (October 2016 September 2017) and CY 2017 (January December 2017) for EPs. 8. How does the Certification Flexibility Rule affect the requirements for CEHRT? With the passage of the Certification Flexibility Rule, providers are no longer required to have 2014 CEHRT to participate in Program Year 2014 if they were unable to fully implement 2014 edition CEHRT due to delays in the availability. Beginning with Program Year 2015 however, all providers must have 2014 CEHRT. 9. How does the Certification Flexibility Rule impact providers who practice at multiple locations with different CEHRT? Providers who practice at multiple separate clinic locations should use the following information to determine how to attest: If more than 50% of your encounters were at locations that fully implemented 2014 edition CEHRT, you do not qualify for a flexibility option and will attest to 2014 measures using reports only from those locations that fully implemented 2014 CEHRT. If there is more than one location, you must obtain MU reports from all locations that fully implemented 2014 edition CEHRT and add the numerators and denominators together. If more than 50% of your encounters were at locations that were unable to fully implement 2014 edition CEHRT due to delays in 2014 CEHRT availability, you qualify to attest using the CERHT flexibility rule. You will need to obtain MU reports from all the locations that were unable to fully implement 2014 edition CEHRT and add the numerators and denominators together for attesting under a flexibility option. 37

38 Part 12: ACRONYMS Acronym Definition AD AGENCY AIU ARNP CEHRT CQMs CY EH EHR EP FMMIS FQHC HIE HIT HITECH HRSA HMO MAPIR MU ONC PA PMS PV REC RHC Additional Documentation Form Agency for Health Care Administration (AHCA) Adopt, Implement, Upgrade Advanced Registered Nurse Practitioner Certified Electronic Health Record Technology Clinical Quality Measures Calendar year Eligible Hospital Electronic Health Record Eligible Professional Florida Medicaid Management Information System Federally Qualified Health Center Health Information Exchange Health Information Technology Health Information Technology for Economic and Clinical Health Act Technical Assistance Health Resource and Services Administrations Health Maintenance Organization Medical Assistance Providers Incentive Repository (online application) Meaningful Use Office of the National Coordinator for Health Information Technology Physician Assistant Practice Management System Patient Volume Regional Extension Center Rural Health Center 38