S.C. Medicaid EHR Incentive Program: Incentives for Eligible Hospitals August 28, 2012 1
Medicare and Medicaid EHR Incentive Programs The American Recovery and Reinvestment Act of 2009 (ARRA) provides for Medicare and Medicaid incentive payments for Eligible Professionals (EP) and Eligible Hospitals (EH) as they adopt, implement, or upgrade to certified EHR technology (Year One of the Medicaid EHR Incentive Program); or as they demonstrate meaningful use of certified EHR technology.
Eligible Hospitals (EH) An acute care hospital, defined as a health care facility with: An average length of patient stay of 25 days or fewer A CMS Certification Number (CCN) with last four digits in range of 0001-0879 or 1300-1399 A children s hospital, defined as a separately certified children s hospital with a CCN with last four digits in range of 3300-3399. An EH that meets the requirements of both the Medicare and Medicaid incentive programs may receive incentives from both programs. 3
An EH must: Additional Requirements for the EH Meet at minimum a Medicaid patient volume threshold of 10%. (A children s hospital is not required to meet Medicaid patient volume requirements.) Meet the requirements of AIU (option for first participation year only), or MU. Have no state or federal exclusions that prevent receipt of federal funding. Be actively enrolled in the S.C. Medicaid Program. 4
Participation Year (Payment Year) An EH that qualifies for the incentive payment may begin to receive the incentives in any year from 2011 to 2016. A Participation Year (aka Payment Year) is defined in terms of a federal fiscal year (FFY). For example, the 2012 Participation Year is October 1, 2011 September 30, 2012. Attestation Tail Period: The S.C. Medicaid EHR Incentive Program allows an additional two months within which to complete the attestation process.
First Step: Register with CMS! CMS Registration & Attestation System Eligible providers who wish to participate in either the Medicare or Medicaid program must first register with CMS Registration & Attestation System (aka NLR). The official Web site for the CMS Medicare and Medicaid EHR Incentive Program is: www.cms.gov/ehrincentiveprograms CMS EHR Information Center is open to assist with inquiries: 1-888-734-6433, 6:30 a.m. until 5:30 p.m. (Eastern Time), Monday through Friday, except federal holidays. 6
First Step: Register with CMS! CMS Registration & Attestation System Important Registration Note: To participate in both the Medicare and the Medicaid incentive programs in the same year, select "Both Medicare and Medicaid" during the CMS registration process. An EH that registers only for the Medicaid program (or only the Medicare program) will not be able to manually change their registration (i.e., change to "Both Medicare and Medicaid," or from one program to the other) after a payment is initiated.
First Step: Register with CMS! CMS Registration & Attestation System Important Note: Once successfully registered with CMS, we recommend that you do NOT return to your CMS account unless you need to modify registration information. If you return to the CMS account (even just to view without modifying your data), you must take steps to resubmit your registration with CMS. A CMS status of Registration Started/Modified, or In Progress, indicates the registration is NOT in a submitted status. 8
SCDHHS Validation of CMS Registration CMS transmits registration to the S.C. State Level Repository on a nightly basis. The SCDHHS HIT Division validates that the EH is licensed, enrolled as a Medicaid provider, and is not excluded from receiving federal funds. After this validation pre-check, HIT sends info to CMS to accept the registration, and opens the attestation tool. (CMS sends an email to the EH to remind them to proceed with attestation.) 9
SCDHHS Validation of CMS Registration In order for incentive payments to process through the S.C. Medicaid Management Information System, (MMIS), the NPI used in the CMS registration must be one that is associated with the Medicaid ID for inpatient hospital in the MMIS. During the pre-check process, HIT will notify the EH if the EH NPI is not one associated with inpatient hospital. The EH will need to send a request to Medicaid Provider Enrollment to tie the NPI to an active Medicaid ID for an inpatient provider type. 10
Questions about registration? 11
Next Step: Attestation with S.C. Medicaid The SLR is available at www.scdhhs.gov/slr. Please allow 24-48 hours after successful CMS registration before attempting to access the SLR. To log in to the SLR attestation tool, use the provider NPI and the CMS Registration ID. The CMS Registration ID remains the same for all participation years. If you have not retained your CMS Registration ID, contact the CMS EHR HelpDesk for assistance. 12
Eligibility to Participate 12-Month Cost Report For an Eligible Hospital, the law defines a Payment Year in terms of a federal fiscal year (FFY) beginning with FFY2011. The EH will use the cost report for the full 12-month hospital cost report period that ends in the FFY preceding the participation year.
Cost Report Period (Example: 2012 PY) For the 2012 Participation Year (10/1/11-9/30/12), the base year cost reporting period that will be used in the payment calculation will be as follows: Fiscal Year End Month Cost Report Year End January 2011 February 2011 March 2011 April 2011 May 2011 June 2011 July 2011 August 2011 September 2011 October 2010 November 2010 December 2010
Attestation: AIU or MU? An EH may attest to AIU (Adopt, Implement, or Upgrade) in Year One of participation in the Medicaid EHR Incentive Program. The EH must attest to MU (meaningful use) in Year One of participation in the Medicare EHR Incentive Program. All other participation years in both Programs are paid by meeting the MU objectives. 15
Attestation: MU Reporting Period Two factors determine the MU EHR reporting period for an EH eligible for both the Medicare and the Medicaid EHR Incentive Programs: The EH Participation Year Timing of the attestation to the two Programs. Any 90-day meaningful use reporting period is always followed by a full-year reporting period in the following Participation Year. (The two Programs align for meaningful use.) 16
Example: Attestation: MU Reporting Period In 2011, an EH attests to Medicaid under AIU, then to Medicare using a 90-day MU reporting period. In 2012, the EH will need to attest using a full-year MU reporting period for both Programs. Example: In 2011, an EH attests to Medicaid under AIU, but does not attest to Medicare. The EH waits until 2013 to attest to MU. The MU reporting period in 2013 would be a 90- day MU reporting period for both Medicare and Medicaid. 17
State Level Repository (SLR) Sign-In Screen 18
State Level Repository Attestation Tool Summary of Screens The SLR attestation tool is comprised of a series of screens that display data and allow collection of attestation data: CMS/NLR Screen Hospital Eligibility Details Screen Incentive Payment Calculations Screen EHR Details Screen MU Questionnaire (Year 2 Only) Document Upload Screen Attestation Screen
State Level Repository Attestation Communication & Alternate Contacts E-mails regarding the EH attestation are sent to the e-mail address on record from the CMS registration. The EH representative may also designate alternate contacts, and request copies of e-mails sent from the SLR, by completing the Alternate Contact screen. Multiple alternate contacts may be added.
State Level Repository Attestation Communication & Alternate Contacts
CMS/NLR Screen 22
SLR CMS/NLR Screen Displays EH registration data from the CMS registration. Possible action required: If data displayed is incorrect, the EH rep must return to CMS to make the correction. Displays S.C. Medicaid ID(s) associated with the EH NPI and TIN provided during registration. Possible action required: If there are multiple choices, the EH must select the Medicaid ID for the inpatient hospital.
SLR CMS/NLR Screen Status Messages PreCheck inprocess: SCDHHS is checking provider eligibility to participate PreCheck_Completed: SCDHHS has completed the eligibility check and the provider may begin attestation Attest_inProcess: Provider has begun the attestation, but has not yet submitted Attest_Completed: Provider has submitted the attestation to the SLR DHHSCheck_inProcess: SCDHHS is checking the provider attestation against requirements DHHSCheck_Completed: SCDHHS has completed the requirements check NLRDupCheck_inProcess: SCDHHS has sent CMS their intent to pay the incentives NLRDupCheck_Completed: CMS has responded to SCDHHS request MMISPayment_inProcess: SCDHHS is processing payment Paid: SCDHHS has disbursed the incentive Ineligible: SCDHHS has found the provider to be ineligible for the incentives Ineligible-CMS: CMS has found the provider to be ineligible for the incentive
SLR CMS/NLR Screen Year One Add screenshot of CMS/NLR Screen
SLR CMS/NLR Screen Year One Add screenshot of CMS/NLR Screen
SLR CMS/NLR Screen Year Two Add screenshot of CMS/NLR Screen View Year One, or Begin Year Two Attestation
Questions about CMS/NLR Screen? 28
SLR Attestation: Hospital Eligibility Details Screen Collects EH attestation data related to: Patient Volume EHR Details (AIU or MU) Growth Rate Medicaid Share Provides templates for required worksheets for EH completion. HIT Hospital Worksheet HIT Volume Calculation Worksheet
SLR Hospital Eligibility Details Screen Patient Volume An EH must meet the Medicaid patient volume threshold of 10%. The formula for calculating patient volume is: *Total Medicaid patient encounters in any representative continuous 90-day (3 month) period in the preceding fiscal year Total patient encounters in that same 90-day (3 month) period *100 *No CHIP beneficiaries may be included in the total Medicaid patient encounters. 30
SLR Hospital Eligibility Details Screen Patient Volume No CHIP beneficiaries may be included in the Total Medicaid Encounters. Select the EH county from the drop-down reference table that is included in the SLR. The SLR will offset the Medicaid encounters by the CHIP percentage for that county when calculating the patient volume. Since this CHIP adjustment factor is required by SCDHHS, this is not included as part of a post-payment audit. 31
SLR Hospital Eligibility Details Screen Patient Volume Encounter: Services rendered to an individual: and Per inpatient discharge where Medicaid paid for part or all of the service, or Medicaid paid all or part of the individual s premiums, co-payments, and/or cost sharing; In an emergency department on any one day where Medicaid paid for part or all of the service, or Medicaid paid all or part of the individual s premiums, copayments, and/or cost sharing. 32
SLR Hospital Eligibility Details Screen Ensure that the attestation of both Medicaid and Total Discharges for the three-month patient volume period includes the sum of the inpatient discharges and E/R visits. Ensure that the Year One three-month patient volume period falls within the base year cost report period being used to determine your Medicaid EHR aggregate incentive amount. 33
SLR Hospital Eligibility Details Screen Patient Volume Additional information to provide: If Nursery, Rehab, or Psych discharges are billed as a bill type 11, the discharges can be used in the calculation. EHs provide more information about these discharges on the HIT Hospital Worksheet. HIT Volume Calculation Worksheet must be completed so that SCDHHS can test the validity of data submitted. 34
SLR Hospital Eligibility Details Screen Ensure that all supporting documentation used to determine the Medicaid Eligible and Total inpatient discharges and E/R visits for the three-month period is uploaded into the SLR. Primary source document will include copies of monthly board minutes or monthly financial/statistical reports prepared by hospital that provides info on discharges, ER visits, etc. Where there is a difference between the number of Medicaid Eligible and Total inpatient discharges and E/R visits reported on the primary source document, in comparison to the number of Medicaid Eligible and Total inpatient discharges and E/R visits reported in the HIT Volume Calculation worksheet, prepare and upload into the SLR a worksheet that will reconcile the difference(s). 35
SLR Hospital Eligibility Details Screen Patient Volume Review EH Checklist. Download and complete HIT Hospital Worksheet, and HIT Volume Calculation Worksheet for upload.
SLR Hospital Eligibility Details Screen EHR Details Adopt: acquiring, purchasing or securing access to certified EHR technology Implement: installing or commencing utilization of certified EHR technology capable of meeting meaningful use requirements Upgrade: expanding the available functionality of certified EHR technology that facilitates meeting meaningful use (e.g., addition of clinical decision support, e-prescribing functionality, CPOE) Meaningful Use: Required for Year Two 37
SLR Hospital Eligibility Details Screen EHR Details The SLR has a specific screen to collect more information about the certified EHR technology (discussed later in this presentation). 38
SLR Hospital Eligibility Details Screen EHR Details
Payment Aggregate EHR Incentive Amount The aggregate EHR incentive amount is the total amount the hospital could receive in Medicaid payments over a theoretical four years of the program. It is the product of two factors: The overall EHR amount, and The Medicaid Share.
Payment Aggregate EHR Incentive Amount - Overall EHR Amount The overall EHR amount is based upon the sum over a theoretical four years of payment where the amount for each year is the product of three factors: An Initial Amount (base of $2Million, plus dischargerelated amount), The Medicare Share (set at 1 by statute), and A Transition Factor applicable to each of the theoretical four years.
Payment Aggregate EHR Incentive Amount- Medicaid Share The Medicaid Share is essentially the percentage of a hospital s inpatient, non-charity care days that are attributable to Medicaid inpatients. The numerator of the Medicaid Share is the sum of: The estimated number of Medicaid inpatient-bed-days, and The estimated number of Medicaid managed care inpatient-bed-days.
Payment Aggregate Incentive Amount- Medicaid Share The denominator of the Medicaid Share is the product of: The estimated total number of inpatient-bed-days for the eligible hospital during that period, and The estimated total amount of the eligible hospital s charges during that period, not including any charges that are attributable to charity care, divided by the estimated total amount of the hospital s charges during that period.
SLR Hospital Eligibility Details Screen- Remember! Ensure that any Medicaid sub provider (i.e., psych or rehab) days and nursery days that may be reported as a Medicaid HMO day on W/S S-3, Part 1, Column 7, Line 2 (i.e. 2552-10) are excluded from the Medicaid HMO days when entering this data into the SLR. 44
SLR Hospital Eligibility Details Screen The SLR Guide for Eligible Hospitals is a reference source to the lines in the cost report that correspond to the data needed for the calculation of the Medicaid Share of the aggregate EHR incentive amount. The SC HIT Payment Calculation Worksheet is also available to provide a summary of W/S references and an estimate of the aggregate payment amount. 45
SLR Hospital Eligibility Details Screen Beyond Year 1 Each participation year, the EH must at least meet the minimum threshold for Medicaid patient volume (10%). Each participation year, the EH will review the information from the first participation year related to Growth Rate and Medicaid Share, and will attest to any changes (if any) from an amended cost report. 46
SLR Hospital Elig Details-Growth Rate & Medicaid Share Year One: Complete all fields for Growth Rate and Medicaid Share.
SLR Hospital Eligibility Details Screen Year Two Year Two: Do you need to revise info provided in Year One s attestation? Information from Year One attestation is displayed. Fields 10-18 are editable. 48
Questions about Patient Volume or Payment Calculation? 49
SLR Incentive Payment Calculations Screen This screen displays the EHR Amount calculations, the Medicaid Share calculations, and the total aggregate EHR incentive payment amount. During the attestation review process, it is possible that the EH will be required to make corrections that could change this estimated aggregate amount. Once the attestation is approved (MMIS Payment in Process), the EH will be able to view the approved amount. Amendments to the EH cost report may impact the aggregate EHR incentive payment amount. 50
SLR EHR Details Certified EHR Technology certified by an ONC- Authorized Testing and Certification Body (ONC-ATCB) and reported to ONC. The ONC Certified Health IT Product List is updated at least weekly and serves as the official listing of certified products. 51
http://onc-chpl.force.com/ehrcert 52
Certified EHR Technology: CHPL Number & CMS Certification ID 53
Certified EHR Technology: CHPL Number 54
Certified EHR Technology: CHPL Number CHPL Product Number 55
Certified EHR Technology: CMS EHR Certification ID Add to Cart to get CMS EHR Certification ID 56
Certified EHR Technology: CMS EHR Certification ID Select this button 57
Certified EHR Technology: CMS EHR Certification ID The CMS EHR Certification ID has 15 characters. 58
SLR EHR Details Screen Year One: Provide the CMS EHR Certification ID, describe the certified EHR technology you have at the time of the attestation, and details about the legal or financial commitment to the technology that meets 100% of the criteria for the Program. Year Two: Review information from Year One. If you have had changes to the certified EHR technology, edit the CMS EHR Certification ID information, and provide a description of the change in the text box. The SLR will check against the ONC Certified Health IT Product List to validate that the CMS EHR Certification ID you enter is a valid ID. 59
SLR EHR Details Screen Year One 60
SLR EHR Details Screen Beyond Year One 61
Questions about EHR Details Screen? 62
SLR MU Questionnaire Screen A hospital that is a meaningful EHR user under the Medicare EHR Incentive Program is deemed to be a meaningful user for Medicaid. A hospital that is dually eligible for both Programs must complete and submit a meaningful use attestation with the Medicare EHR Incentive Program prior to completing the attestation process with Medicaid. The Medicaid EHR Incentive Program receives information from CMS to indicate that the EH has submitted an accepted meaningful use attestation. 63
SLR MU Questionnaire Screen - Medicare Successful If dual-eligible EH has attested successfully to Medicare, this screen displays the MU reporting period used. 64
SLR MU Questionnaire Screen No Medicare Attestation Error message if no MU attestation with Medicare 65
Document Upload Screen 66
SLR Document Upload Screen The EH must upload documentation to support the attestation of Medicaid patient volume. HIT Hospital Worksheet HIT Volume Calculation Worksheet Additional information from EH Checklist The Document Upload Screen may be used during the attestation process, and after an attestation is submitted as required to provide additional requested information.
SLR Document Upload Screen
Attestation Screen 69
SLR Attestation Screen This final screen displays a summary of information from the attestation for review, and an Attestation Statement. To submit, the EH representative signs with initials, and with the EH NPI; then, selects Submit. Once submitted, the attestation is locked for review. The attestation is reviewed both by the HIT Division, and by the SCDHHS Bureau of Reimbursement Methodology and Policy. Questions requiring clarification will be emailed to the email address associated with the CMS registration.
Final Approval by CMS Once SCDHHS finds an attestation to have met the requirements of the Program, a transaction is sent to CMS to notify of intent to pay. CMS checks for federal exclusions; if none are found, the EH registration is Locked for Payment, and SCDHHS may proceed with payment.
Payment of the Incentives The SCDHHS HIT Division will initiate an electronic credit adjustment that will be processed by the MMIS system. Incentive payments are incorporated into the weekly payment schedule within 45 days of final determination that the EH has met the program requirements. The EH representative will be notified of the payment via system-generated e-mail.
Resources www.cms.gov/ehrincentiveprograms SCDHHS Division of Health Information Technology email address: HITSC@scdhhs.gov SCDHHS HIT Web page: www.scdhhs.gov/hit - State Medicaid HIT Plan (SMHP) - SLR User Guide for Eligible Hospitals **Includes cost report line references** - Sample payment worksheet