EHR Medicaid Incentive Payment Program Toolkit

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EHR MedicaidIncentive Payment ProgramToolkitVersion 9.0April 2, 2018EHR Incentive Payment Program Toolkit V9.0Page 1

Table of Contents1INTRODUCTION . 31.1 RESOURCES .32BACKGROUND . 43ELIGIBILITY . 53.13.23.33.44ADDITIONAL REQUIREMENTS FOR THE EP .5ADDITIONAL REQUIREMENTS FOR THE EH .6QUALIFYING PROVIDERS BY TYPE AND PATIENT VOLUME .7OUT-OF-STATE PROVIDERS .7ESTABLISHING PATIENT VOLUME . 74.1 METHODOLOGY FOR DETERMINING ELIGIBLE PROFESSIONAL PATIENT VOLUME.74.2 METHODOLOGY FOR DETERMINING ELIGIBLE HOSPITAL PATIENT VOLUME .125PAYMENT METHODOLOGY FOR ELIGIBLE PROFESSIONALS . 135.1 PAYMENTS FOR ELIGIBLE PROFESSIONALS .136PAYMENT METHODOLOGY FOR ELIGIBLE HOSPITALS . 147ADOPT, IMPLEMENT AND UPGRADE . 178MEANINGFUL USE . 188.1 MU OBJECTIVES FOR 2017 AND 2018 .198.2 MU REPORTING DATA .448.3 CLINICAL QUALITY MEASURES.509PROVIDER REGISTRATION AND ATTESTATION . 529.19.29.39.49.59.6MINIMUM SYSTEM REQUIREMENTS .52REGISTRATION AND ATTESTATION CHECKLIST .53CMS REGISTRATION .54QNET – DUALLY ELIGIBLE HOSPITAL ATTESTATION .55ATTESTATION – REGISTRATION WITH EMIPP .55ATTESTATION DEADLINES .6210HELP DESK INFORMATION . 6211AUDIT INFORMATION . 6311.1 MEDICAID AUDITS .63APPENDIX A – EP ATTESTATION DISCLAIMER LANGUAGE . 65APPENDIX B – EH ATTESTATION AND DISCLAIMER LANGUAGE . 66APPENDIX C – HISTORICAL MEANINGFUL USE INFORMATION . 671PREVIOUS PROGRAM YEARS .6722014 SPECIFIC.6932015 SPECIFIC.7142016 SPECIFIC.73MEANINGFUL USE OBJECTIVES FOR 2016.73APPENDIX D – TOOLKIT REVISION HISTORY . 82EHR Incentive Payment Program Toolkit V9.0Page 2

1 INTRODUCTIONThe Illinois EHR Medicaid Payment Incentive Program (EHRPIP) will provide incentive payments toeligible professionals (EP), eligible hospitals (EH) and critical access hospitals (CAHs) as they adopt,implement, upgrade or demonstrate meaningful use of certified EHR technology. This toolkit will helpguide participants complete the Illinois EHRPIP attestation process.1.1Resources1.1.1 Websites42 CFR Parts 412, 413, 422 et al. Medicare and Medicaid Programs; Electronic Health RecordIncentive Program Final Rule and other legislation:o 2010 Stage 1 Final Ruleo 2012 Stage 2 Final Ruleo 2014 Modifications (Flexibility Rule)o 2015 (Modifications to Stage 1 & Stage 2 for 2015-2017) & Stage 3 Final Ruleo 2017 IPPS Final Ruleo 2017 OPPS Final Ruleo 2015 ONC CEHRTo 2018 IPPS Final Ruleo MACRA/MIPS Final RuleEHR Medicaid Incentive Payment Program system (eMIPP) Portal located at:https://IMPACT.illinois.govMedicare and Medicaid Electronic Health records (EHR) Incentive Program located athttp://www.cms.gov/EHRIncentivePrograms/Office of the National Coordinator for Health Information Technology located .1.2Regional Extension CentersThe U.S. Department of Health and Human Services (DHHS), Office of the National Coordinator forHealth Information Technology (ONC), has awarded two Illinois applicants with Regional ExtensionCenter (REC) grants. The federal REC program (officially known as the Health Information TechnologyExtension Program) was developed to assist health professionals in implementing and becoming“meaningful users” of electronic health records.The two REC awardees are: ILHITREC, a consortium led by Northern Illinois University, serving all areasof Illinois outside the 606 Zip codes; and CHITREC, a consortium led by Northwestern University, servingthe city of Chicago. The two Illinois RECs provide outreach and support services to thousands of primarycare providers and hospitals, throughout the state. The RECs provide a full range of assistance related toEHR selection, EHR training, and the attestation process while providing guidance with meaningful useissues. The RECs also administer an EHR Incentive help desk.The Illinois Department of Healthcare and Family Services (HFS) is working cooperatively with theseRECs to coordinate resources and achieve the state’s goals for health information technology. The RECwebsites are listed below:EHR Incentive Payment Program Toolkit V9.0Page 3

IL-HITREC (Statewide Consortium)www.ilhitrec.orgP.O. Box 755, Sycamore, IL 60178Phone: 815-753-1136Fax: 815-753-2460Email: info@ILHITREC.org1.1.3CHITREC (Chicago Consortium)http://chitrec.org/750 N. Lake Shore Drive, 9th FloorChicago, Illinois 60611Phone: 312.503.2986Fax: 312.503.6743Email: info@chitrec.orgEHR Incentive WorkgroupA bi-weekly meeting is held with representatives from HFS and numerous provider groups to discussEHR Incentive Program activities. To request joining the meeting’s distribution list, please emailHFS.EHRINCENTIVE@illinois.gov.2 BACKGROUNDThe Centers for Medicare & Medicaid Services (CMS) has implemented, through provisions of theAmerican Recovery and Reinvestment Act of 2009 (ARRA), incentive payments to eligible professionals(EP) and eligible hospitals (EH), including critical access hospitals (CAHs), participating in Medicare andMedicaid programs that are meaningful users of certified EHR technology. The incentive payments arenot a reimbursement, but are intended to encourage EPs and EHs to adopt, implement, or upgradecertified EHR technology and use it in a meaningful manner.Use of certified EHR systems is required to qualify for incentive payments. The ONC has issued rulesdefining certified EHR systems and has identified entities that may certify systems. More informationabout this process is available at hr-incentivescertification.Goals for the national program include: 1) enhance care coordination and patient safety; 2) reducepaperwork and improve efficiencies; 3) facilitate electronic information sharing across providers, payers,and state lines and 4) enable data sharing using state Health Information Exchange (HIE) and theNational Health Information Network (NHIN). Achieving these goals will improve health outcomes,facilitate access, simplify care and reduce costs of health care nationwide.HFS will work closely with federal and state partners to ensure that the Illinois Medicaid EHRPIP fits intothe overall strategic plan for the HIE, thereby advancing national and Illinois goals.Both EPs and EHs are required to begin by registering at the national level with the CMS Medicare andMedicaid Registration and Attestation System (RAS) at CMS’ official Web site for the Medicare andMedicaid EHR Incentive Programs. The site provides general and detailed information on the programs,including tabs on meaningful use, clinical quality measures, certified EHR technology, paymentadjustments and hardship exceptions, Stage information and frequently asked questions.EHR Incentive Payment Program Toolkit V9.0Page 4

3 ELIGIBILITYEPs and EHs must begin the program no later than program year 2016. The first tier of provider eligibilityfor the EHRPIP is based on provider type and specialty. If the provider type and specialty for thesubmitting provider in the IL MMIS provider data base does not correspond to the provider types andspecialties approved for participation in the EHRPIP, the provider will be notified of disqualification.The following providers and hospitals are potentially eligible to enroll in the IL Medicaid EHRPIP:EP Type and SpecialtyEH Type and Specialty PhysicianPhysician Assistant (practicing in a FQHC or RHCled by a Physician Assistant): An FQHC or RHC isconsidered to be PA led in the following instances:o The PA is the primary provider in a clinic(e.g., part time physician and full time PAin the clinic)o The PA is the clinical or medical directorat a clinical site of the practiceo The PA is the owner of the RHCPediatrician: Any provider who is Board Certifiedas a Pediatrician or has at least 90% of MedicaidRecipients Under the Age of 21.Nurse PractitionerCertified Nurse MidwifeDentistOptometristAcute Care HospitalChildren’s HospitalCritical Access HospitalNote: Some provider types who are eligible for the Medicare program, such as podiatrists andchiropractors, are not currently eligible for the IL Medicaid EHRPIP.3.1Additional requirements for the EPTo qualify each year for an EHR incentive payment , the EP must:1. Meet one of the following patient volume criteria in any 90 consecutive days during the precedingcalendar year or twelve months prior to the attestation date:a. Have a minimum of 30 percent patient volume attributable to individuals receiving Medicaidfunded services; orb. Have a minimum 20 percent patient volume attributable to individuals receiving Medicaidfunded services, and be a pediatrician (for the purposes of the Illinois Medicaid EHRPIP, apediatrician is defined as a Medicaid enrolled provider who serves 90% of patients under theage of 21 based on the age of the patient at the time the service is rendered or a Medicaidenrolled provider with a valid, unrestricted medical license and board certification in Pediatricsthrough either the American Board of Pediatrics or American Osteopathic Board of Pediatrics);orc. Practice predominantly in a FQHC or RHC and have a minimum 30 percent patient volumeattributable to needy individuals (For this program, practicing predominantly in an FQHC/RHCEHR Incentive Payment Program Toolkit V9.0Page 5

2.3.4.5.means 50% or more of the total patient volume for the EP over a six-month period is at anFQHC/RHC).Have no sanctions and/or exclusions.Not be deceased.Not have 90% or more of the patient encounters take place in a hospital setting.Be enrolled and in good standing with Illinois Medicaid.An individual EP may choose to receive the incentive him/herself or assign it to a Medicaid contractedclinic or group to which he/she is associated. The tax identification number (TIN) of the individual orentity receiving the incentive payment (“payee”) is required when registering with CMS Registration andAttestation System (RAS) and must match a TIN associated to the individual provider in the HFS IMPACTprovider enrollment system. The system will check for the following: Provider is enrolled with HFSProvider status is active and in good standingProvider/Payee combination is validProvider is enrolled with HFS in an eligible Provider TypeProvider is not sanctionedProvider is not deceasedIf any of the checks performed above fail, the provider will not be able to attest. For contactinformation please see Section 10 HELP DESK INFORMATION.3.2Additional requirements for the EHTo qualify each year for an EHR incentive payment, the EH must be:1. An acute care hospital (includes CAH) that has at least a 10 percent Medicaid patient volume in theprevious calendar year for each year the hospital seeks an EHR incentive payment; or2. A children’s hospital (exempt from meeting a patient volume threshold).Hospital-based providers (90% or more of their patient encounters take place in a hospital setting) arenot eligible for the EHR incentive program.EHR Incentive Payment Program Toolkit V9.0Page 6

3.3Qualifying Providers by Type and Patient VolumeProviders by ician Assistantswhen practicing at anFQHC/RHC led by aphysician assistantNurse PractitionerAcute care hospitalChildren’s Hospital3.4Minimum Percent Patient Volume(90-day period)30%20%30%30%30%Or the Medicaid EPpractices predominantlyin a FQHC or RHC with30% “needy individual”patient volume threshold30%10%No minimumOut-of-State ProvidersThe IL Medicaid EHRPIP welcomes any out-of-state provider to participate in this program as long asthey are enrolled in IL Medicaid. Illinois must be the only state they are requesting an incentivepayment from during that participation year. For audit purposes, out-of-state providers must makeavailable any and all records and claims data considered to be pertinent to an audit. Records must bemaintained as applicable by law in the state of practice or Illinois, whichever is deemed longer.4 ESTABLISHING PATIENT VOLUMEAn Illinois Medicaid provider must meet patient volume requirements annually. The patient fundingsource identifies who can be counted in the patient volume: Title XIX (TXIX) – Medicaid and Title XXI(TXXI) – CHIP (Children’s Health Insurance Program).There are several items to be considered when calculating Medicaid patient volume, including: Methodology for determining patient volume Individual volume vs. group proxy Out-of-state encounters4.1Methodology for Determining Eligible Professional Patient VolumeAll EPs (except EPs predominantly practicing in an FQHC/RHC) will calculate patient volume based onencounters with Medicaid (billed to HFS) and out-of-state Medicaid patients. The EHR statute allows foran EP practicing predominantly in a FQHC or RHC to consider CHIP patients under the needy individualpatient volume requirements.EHR Incentive Payment Program Toolkit V9.0Page 7

4.1.1Definition of an Eligible Professional Medicaid EncounterFor purposes of calculating EP patient volume, a Medicaid encounter is defined as services rendered onany one day to an individual where the individual was enrolled in a Medicaid program (or a Medicaiddemonstration project approved under section 1115 of the Act) at the time the billable service wasprovided.It also includes Managed Care Organization (MCO) encounters and Dual Eligible (Medicare/Medicaid)encounters.4.1.2Definition of an Eligible Professional Needy Individual EncounterFor purposes of calculating patient volume for an EP practicing predominantly in a FQHC/RHC, a needyindividual encounter is defined as services rendered on any one day to an individual where medicalservices were: Billed to HFS;Furnished by the provider as uncompensated care (charity care); orFurnished at either no cost or reduced cost based on a sliding fee scale determined by theindividual’s ability to pay.4.1.3Calculating Eligible Professional Patient VolumeTo calculate patient volume, providers must include a ratio where the numerator is the total number ofMedicaid (billed to HFS) patient encounters (or needy individuals for FQHCs and RHCs) treated in any 90day period in the previous year or the twelve months prior to the attestation date , and thedenominator is all patient encounters over the same period. The numerator must consist of allencounters billed to HFS during the 90-day period; the denominator must consist of all encounters billedto any entity during the 90-day period.To calculate Medicaid patient volume, EPs (except those practicing predominantly in a FQHC/RHC) mustdivide: The total Medicaid encounters billed to HFS or out-of-state Medicaid patient encounters in anyrepresentative, continuous 90-day period in the preceding calendar year or twelve months prior tothe attestation date; by The total patient encounters in the same 90-day period.Total Medicaid Member Encounters billed to HFS inany 90-day period in the preceding calendar year ortwelve months prior to the attestation date*100 %Medicaid patient volumeTotal Patient Encounters in that same 90-day periodTo calculate needy individual patient volume, EPs practicing predominantly in a FQHC/RHC must divide: The total needy individual patient encounters in any representative, continuous 90-day period in thepreceding calendar year or twelve months prior to the attestation date; by The total patient encounters in the same 90-day period.EHR Incentive Payment Program Toolkit V9.0Page 8

4.1.4Individual vs. Group Patient VolumeMedicaid patient volume thresholds may be met at the individual level (by provider NPI) or at the grouppractice level (by organizational NPI/TIN). EPs may attest to patient volume under the individualcalculation or the group/clinic calculation in any participation year.4.1.5EPs Using

Apr 02, 2018 · o 2015 (Modifications to Stage 1 & Stage 2 for 2015-2017) & Stage 3 Final Rule o 2017 IPPS Final Rule o 2017 OPPS Final Rule o 2015 ONC CEHRT o 2018 IPPS Final Rule o MACRA/MIPS Final Rule EHR Medicaid Incentive Payment Program system (eMIPP) Portal

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