GENERAL: GEN-1 How do I prove that I have adopted, implemented or upgraded (AIU) a system? To prove AIU of a system, documentation of the EHR system must be attached during the attestation process. The proof should be applicable to the type of attestation (Adoption, Implementation or Upgrade) and must include: Include in the Step 3 Brief Description the Vendor name, software name and software version Software license or service agreement Invoice/Work Order Screen shot of the ONE Certified HIT Product List (CHPL) site (http://oncchpl.force.com/ehrcert?q=chpl) GEN-2 GEN-3 GEN-4 GEN-5 GEN-6 GEN-7 What types of encounters are eligible under the new patient encounter definition? If I have separate Modules for the certified EHR systems that we have, how do I get a Medicaid certification ID? What is the estimated length of time to complete the process from registering at the state level and pushing submit for attestation? What if I am on the waiting list for CIIS? How do I proceed with my attestation to Meaningful Use (MU)? If Medicaid is a secondary form of insurance for an encounter, can it be counted for eligibility purposes? How many times can I transfer my attestation between States? Patient encounters under the new definition can include service rendered on any one day to a Medicaid-enrolled individual, regardless of payment liability. This includes zero-pay claims. For separate modulated systems, a certification ID can be received through ONC. Please visit this link for more information: http://oncchpl.force.com/ehrcert?q=chpl Providers will have access to Colorado-specific Excel workbooks that will have step-by-step walk-through of the information required for attestation. If all required information is organized and valid, attestation should take no longer than 30-45 minutes for an AIU attestation and 45-60 minutes for an MU attestation. If you are on the waiting list for CIIS when required to attest to Meaningful Use, an exclusion may be taken until you are removed from the CIIS waiting list. A copy of the email from CIIS is required to be uploaded if claiming the exclusion. Yes, with the change in the patient encounter definition, Medicaid can either pay for all, part or none of the encounter as long as the patient is enrolled in Medicaid at the time of service. Eligible Professionals and Eligible Hospitals can transfer between state Medicaid EHR Incentive Programs multiple times prior to and after receiving their first Medicaid EHR Incentive Payment; however, they can only receive one payment in any given Page 1 of 7
program year. GEN-8 In order to receive payment, do I have to have a Medicaid Payer ID? Yes. In the case of both Eligible Professionals and Eligible Hospitals, each Eligible receiving an incentive payment must have their own individual Medicaid Payer ID. Medicaid Payer IDs can be obtained from the State of Colorado by contacting Colorado Medicaid Provider Services (Xerox) at 1.800.237.0757. GEN-9 GEN-10 GEN-11 GEN-12 GEN-13 GEN-14 Can I receive two payments in one year for the first two years of the program (AIU and MU) since the reporting period is only 90-days? I logged into the CMS registration site and the status of my registration says, Sent to State for Approval. When can I expect this to change? What year is the last year that I can attest to Year 1 AIU of the Medicaid EHR Incentive Program? What is the difference between Program Year, Representative Period and EHR Reporting Period? From what timeframe must the 90-day Representative Period be calculated? Do I have to prove eligibility each year that I attest to the Medicaid EHR Incentive Program? No. Once an AIU or MU attestation is submitted during a Federal Fiscal Year (for EHs) or Calendar Year (for EPs), the CO R&A will lock until the next program year opens. The Sent to State for Approval status indicates that you must log in to the CO R&A to complete your attestation. Once the State has reviewed and approved your attestation, this status will change in the CMS registration system. The last year that Eligible Hospitals or Eligible Professionals can start their AIU attestation is 2016 for the. The Program Year is the year for which you are requesting payment (Year 1, Year 2, etc.). The Representative Period (also called an eligibility period) is the 90-day timeframe in which you will need to prove the required Medicaid Patient Volume. The EHR Reporting Period is the timeframe for which EHR Meaningful Use data are being reported. For both Eligible Hospitals and Eligible Professionals, the Representative Period may be any 90-day consecutive period from the previous calendar year OR, preceding 12-month period from the date of attestation Yes, eligibility must be established each program year during attestation and subject to the program year s eligibility calculation guidelines. Page 2 of 7
ELIGIBLE PROFESSIONALS: EP-1 As a group of physicians, can we have an administrator do the attestation process for us? Yes, but each Eligible Professional must sign the completed attestation agreement as acknowledgement that, even though attesting under group volumes, each EP attests as an individual. In addition to the group login to the CO R&A, each EP will need to create an individual login and submit their attestation once they have been notified by the group administrator. EP-2 EP-3 EP-4 EP-5 EP-6 EP-7 Which steps of the attestation process can be done by the administrator for a group and which must be done by the Eligible Professional? Can EPs count dual-eligible patients for percentages for eligibility calculations? Does the 90-day Representative (Eligibility) Period have to fall in just one calendar year or can it cross calendar years? Is my 90-day MU EHR Reporting Period the same as my Representative Period? Where do I enter where I would like my payment to go? If a practice has five EPs but they all bill under one provider, can I attest for these EPs? The administrator for a group can complete Steps 1-3 of the attestation process under the group login. The EP must use their individual login to complete Steps 4-5 which is the signing and uploading of the attestation agreement along with submitting their attestation to the State. Yes, as long as the patient was enrolled in Medicaid during the 90-day eligibility period. The consecutive 90-day period can either fall within the previous calendar year or any consecutive 90-day period in the 12 months prior to the date of attestation, so it is possible that the 90-day Representative Period crosses a calendar year. No, it doesn t need to be, but certainly can. The 90- day MU EHR Reporting Period will fall in the current calendar year whereas the Representative Period can either fall within the previous calendar year or any consecutive 90-day period in the 12 month prior to the date of attestation. When an EP registers at the CMS website for the Medicaid EHR Incentive Program, there is a field in which the EP can specify where the payment should be sent. Note that if an EP is assigning payment to your practice, the EP must be affiliated with the practice in the Colorado Medicaid Management Information System (MMIS). No. The EPs are considered Rendering Providers of the billing provider. The Department cannot issue a check/payment to a rendering provider. If the rendering provider would like payments sent to them individually, they must register with the State as their own provider and obtain a Medicaid ID number. Once Page 3 of 7
the rendering provider has their own Medicaid ID and can prove the 30% eligibility under their own ID, you can attest. EP-8 How long past the end of the Calendar Year do I have to attest for payment? The deadline for EPs to attest for any program year is 60 days past the end of the calendar year. EP-9 EP-10 EP-11 EP-12 EP-13 EP-14 EP-15 EP-16 If our clinic is not a designated FQHC or RHC, can we use CHP+ or CICP in our Representative Period calculation? If our practice/clinic is attesting as a group, do we all have to meet MU measures? If our practice/clinic has attested as a group and we have received our payment, can we add a recently-hired, qualified EP that has seen Medicaid patients but was not present in our 90- day period from the previous year for eligibility in our group calculation? If our practice/clinic is attesting as a group, can we use differing 90-day eligibility periods for each EP? Can Colorado Access and Rocky Mountain Health Plan Medicaid count towards eligibility volumes? If one doctor in a practice/clinic attests to Medicare, can the remaining providers use the group option to attest to Medicaid? If our practice/clinic is a group of pediatricians and some of the EPs hit 30% while other hit between 20-30%, will the EPs that hit 30% get paid the full incentive amount? If our practice/clinic is NOT a designated FQHC or RHC, can we include our PA No. Only Medicaid-enrolled patients with encounters (including zero-pay) may be used for calculating patient volume in non-fqhc and non-rhc facilities. Yes. Each EP will need to demonstrate that they have met the full requirements of Meaningful Use in order to receive their Year 2-6 payments. Group attestations are only used to calculate volume for eligibility. No. CMS does not allow EPs to be added to a group once a payment has been received in a program year. Any new EPs must register and attest as individuals following all current eligibility rules for that program year. No. A group attestation must use the same 90-day Representative (eligibility) period for all EPs attesting with the group. Yes, as long as the encounters were billed to / a claim for filed for Medicaid (zero-pay included) and the patient was enrolled in Medicaid during the Representative period. These do not include CHP+ or CICP. Yes as long as all of the EPs listed in the group are eligible to receive incentive payments following all of the eligibility guidelines. No. Eligibility as a group looks solely to what the group qualifies for and determines that payment based on the group eligibility data. Therefore, if the total group eligibility volume falls between 20-30%, then the payment made per EP will be 2/3 of the full incentive amount. If you choose the attest for each of your pediatricians individually, those EPs at 30% will receive full payment and those between 20-30% will receive a 2/3 payment. No. If you are attesting as a group, only those providers that are eligible for the incentive program Page 4 of 7
encounters in our group eligibility? can be included in your group eligibility. PAs are not eligible unless practicing in an FQHC or RHC and that clinic is so-led by a PA. EP-17 If a PA is eligible, how do we count encounters if they bill under a provider? PAs can use their own encounters even if the claims are filed under another provider as long as there is an auditable trail showing that the PA did actually consult on those encounters. The PA will need their own Medicaid ID in order to receive payment and a letter, signed by either the supervising physician or practice executive will need to be included with the attestation. EP-18 EP-19 EP-20 EP-21 EP-22 How does a practice/clinic handle a case in which an EP has a hostile termination with the practice/clinic? What are the requirements to meet Stage 1 Meaningful Use for the Colorado Medicaid EHR Incentive Program? What is the timeframe for an EP application for AIU? What is the timeframe for an EP attestation to Stage 1 90-day Meaningful Use? What is the difference between Individual Eligible Professional Volume and Group Volume? According to the Final Rule (2010), the Medicaid EHR Incentive money belongs to the individual EP. If there is a hostile termination, the incentive money, per the Final Rule, belongs to the terminated EP. Please make sure that you consult your legal representation. You must show that you are meaningfully using a certified EHR and must meet all of the Stage 1 Meaningful Use requirements that CMS has established. EPs must meet 14 Core Objectives, 5 Menu Objectives and 6 Clinical Quality Measures. EPs must also have at least 80% of patients with records in the certified EHR technology and have at least 50% of encounters at locations where certified EHR technology is present. Colorado s Medicaid EHR Incentive Program opened for AIU attestation in March 2012. The last date to start a new AIU attestation is Program Year 2016. For those EPs that attested to AIU in 2012, MU attestations will open April 2013 with an EHR Reporting Period of 90-days. Program Years 2013 and 2014 will only require a 90-day reporting period for MU data. Starting in Program Year 2015, all EPs will attest to Meaningful Use with a 1 year EHR Reporting Period regardless of MU Stage. EPs attesting as a group can choose to use the Group s overall encounter data instead of each EPs qualifying on his/her own individual encounter volumes. Choosing to use the group s volumes as a proxy to the individual encounter volumes requires that all EPs in the group use the same group volumes in their individual attestations. The volume should Page 5 of 7
include both Medicaid and Total Encounters from all eligible members of the group. EP-23 EP-24 EP-25 EP-26 EP-27 EP-28 EP-29 EP-30 EP-31 Can an Advanced Practice Nurse, Physician s Assistant or Dentist qualify as a Pediatrician using Medicaid Patient Volume between 20-30%? Can a patient visit for the purposes of a lab test only be counted as an encounter? If a provider-based clinic has an NPI associated with a hospital, can they attest as individual providers? What happens if our practice changes Certified EHRs between program years? Is there a requirement for the amount of patients that need to have records in the EHR to attest to MU? If our practice attested as a Group last year, can we change the members of that Group this year or attest as individuals? If our practice is attesting as a Group, can we have EPs that are attesting to AIU and MU in the same Group? FAQ EP-12 states that the 90-day Representative (eligibility) Period must be the same for all EPs in my group. Does that mean that they all must have the same EHR Reporting Period if they are attesting to MU? If I have an EP that wants to skip the AIU attestation and attest to MU, is that No. CMS specifies that in order to qualify for the Medicaid EHR Incentive Program using a pediatrician percentage between 20-30% Medicaid Patient Volume, the EP must be a physician, either an MD or DO. As long as the patient was enrolled in Medicaid at the time of the lab test, whether Medicaid paid for the part or the entire test or not, and as long as the test was attributed to one EP, encounters like these can be counted toward Medicaid Patient Encounters. Yes. When the EPs create their own login for the CO R&A, they will select the practice location on the Is This You? page. If you are in the middle of attesting for a group of EPs when an upgrade or change in EHR vendors occurs, finish your current program year attestations using the previous Certified Health IT Product List ID (CHPL ID). You can update to the new system configuration s CHPL ID during the next program year attestation. Yes. Meaningful Use objectives are based solely on encounters that occurred at locations where the certified EHR is available. In order to qualify for the EHR Incentive MU payments, 80% of patients must have records in the EHR. Yes. In the CO R&A, Groups will need to be rebuilt for each payment year. At this time, you can either add or remove EPs from your group. You may also choose to attest each EP individually if they reach the required patient volume independently. Yes. Because the CO R&A requires that a new Group is built each year, you may have EPs in different payment years. No. If you are attesting as a Group, each EP attesting to MU can have a different EHR Reporting Period. Group attestations are only used to establish eligibility. Even though your Group may be sharing encounter volumes to be eligible, they are each attesting using their individual Meaningful Use data. EPs can certainly skip the first year AIU attestation and attest to MU right away if they so choose. First Page 6 of 7
allowed and would they receive the year payment, regardless of AIU or MU, is $21,250.00 higher or the lower payment? (or 2/3 for pediatricians attesting at 20%). Timeline for if Program Year 1 (AIU) = 2012 Year Eligibility Period 1 MU Stage MU Data Period Deadline for Payment Amount 2 2012 90 day AIU n/a 2.28.13 $21,250 2013 90 day 1 90 day 2.28.14 $8,500 2014 90 day 1 90 day 3 2.28.15 $8,500 2015 4 90 day 2 1 year 5 2.28.16 $8,500 2016 90 day 2 1 year 2.28.17 $8,500 2017 90 day 3 1 year 2.28.18 $8,500 Timeline for if Program Year 1 (AIU) = 2013 Year Eligibility Period 1 MU Stage MU Data Period Deadline for Payment Amount 2 2013 90 day AIU n/a 2.28.14 $21,250 2014 90 day 1 90 day 3 2.28.15 $8,500 2015 4 90 day 1 1 year 5 2.28.16 $8,500 2016 90 day 2 1 year 2.28.17 $8,500 2017 90 day 2 1 year 2.28.18 $8,500 2018 90 day 3 1 year 2.28.19 $8,500 1 For Program Year 2012, the eligibility period can be only from 2011. and beyond can be either from the previous calendar year or the 12 month period preceding attestation. 2 Pediatricians who qualify with 20-30% Medicaid encounter volume will receive a 2/3 payment. 3 Regardless of MU Stage, all EPs can submit their MU data based on a 90-day consecutive period in 2014. 4 Any information for 2015 and beyond is subject to change based on new or changed regulations to the EHR Incentive Program. 5 One year of EHR Reporting Data is based on the calendar year and cannot cross calendar years. Page 7 of 7