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The final rule gives MEIP up to 45 days from the date the EP, EH or CAH receives a ”Payment Pending” status in MEIP. It is possible that the decision to reimburse or deny would be extended if MEIP is awaiting additional supporting documentation from the EP, EH or CAH. DHS cannot provide an opinion on the best timing for your incoming revenue.
If an EP or an EH returns to its’ CMS record and exits without clicking on Submit, the CMS system alters your status and MEIP does not receive confirmation of the completed CMS registration. To correct, return to the CMS Registration site and submit any changes to trigger the update process and forward the record to MEIP.
To participate in the Minnesota EHR incentive program, EPs are required to demonstrate a patient volume of at least 30 percent Medicaid patients over a 90-day period in the prior calendar year or in the 12 months before attestation. CMS allows 29.5 percent to 29.9 percent to be rounded up to 30 percent for purposes of determining patient volume. Similarly, pediatric patient volume may be rounded from 19.5 percent and higher to 20 percent. Finally, acute care and critical access hospitals (CAH) are required to demonstrate a patient volume of at least 10 percent Medicaid patients over a 90-day period in the fiscal year preceding the hospital’s payment year or in the 12 months before attestation. Hospitals’ patient volume from 9.5 percent to 9.9 percent may be rounded up to 10 percent. For more information, please see CMS FAQ8037.
No, Medicaid providers are not required to participate in consecutive years of the EHR incentive program. Providers who skip years of participation will resume the progression of Meaningful Use (MU) where they left off. All providers must meet AIU or Modified Stage 2 for their first program year.
Note: Eligible professionals who wish to maximize their incentive payments must qualify for an incentive payment for six years and begin receiving payments no later than the end of the grace period in 2017. Eligible professionals cannot receive payments after 2021. Also note that after 2016, eligible hospitals must have participated in the previous year in order to receive a payment.
MU attestation will be an ongoing process that all providers must participate in as a result of being a provider for Medicare and Medicaid. To ensure that you receive your incentive payments from MEIP, you need to meet the following dates in order to participate.
EPs may skip a year at any point in the program. If an EP begins the EHR incentive program in 2016 and skips a PY past that point, the EP will be unable to receive the full amount for the incentive payments.
Beginning with PY 2016, all EHs must receive a payment in 2016 and each consecutive year thereafter to receive their full allotment of incentive payments. Any skipped or missed years for attestation beginning with PY 2016 ends the incentive payments for that EH.
No, Medicaid EHR incentive payments are exempt from the mandatory reductions.
Yes, while there are no payment adjustments under the Minnesota EHR incentive program, Medicaid EPs who are also paid under Medicare could be subject to payment adjustments if they are not meaningful EHR users for an applicable reporting period. Adopting, implementing and upgrading EHR technology is not considered meaningful use for these purposes.
We encourage you to familiarize yourself with the details of the Medicare payment adjustment by reviewing the Stage 1 and 2 final rules at 42 C.F.R. Part 495. For more information, please see CMS FAQ7727.
Physician’s assistants practicing in tribal or urban facilities can qualify for the Minnesota EHR incentive program. Some language on other state sites indicates they do not include tribal or urban facilities since they do not have them in their state.
EPs practicing in a tribal or urban facility can include “needy individual” encounters to meet the minimum patient volume requirement.
Yes, notify MHCP Provider Enrollment in writing of any change in information, including address changes, provided on the enrollment application. Use Individual Practitioner MHCP Provider Profile Change Form DHS-3535 (PDF) or the Organization MHCP Provider Profile Change Form DHS-3535A (PDF), as appropriate.
An EP is given the option to designate a payee after the EP attests to his or her MPV as an individual or within a group or clinic. The EP can designate themselves as the payee. CMS clarifies in 42 CFR 495.10 of the final rule published on July 28, 2010 (page 44572):
(f) Limitations on incentive payment reassignments. (1) EPs are permitted to reassign their incentive payments to their employer or to an entity with which they have a contractual arrangement allowing the employer or entity to bill and receive payment for the EP’s covered professional services. (2)(i) Assignments in Medicare must be consistent with Section 1842(b)(6)(A) of the Act and 42 CFR part 424 subpart F. (ii) Medicaid EPs may also assign their incentive payments to a TIN for an entity promoting the adoption of EHR technology, consistent with subpart D of this part. (3) Each EP may reassign the entire amount of the incentive payment to only one employer or entity.
CMS clarifies on page 44446 of the final rule EHR incentive payments and contractual agreements:
Title IV, Division B of the HITECH Act establishes incentive payments under the Medicare and Medicaid programs for certain professionals and hospitals that meaningfully use certified EHR technology. The provisions are not focused solely upon the costs associated with the EHR technology. Rather, as we stated in the proposed rule (75 FR 1849), it focuses upon the adoption, implementation, upgrade, or meaningful use of the technology. However, we do agree that some entities may have to review and/or negotiate current contractual arrangements to address the transfer of the incentive payments. The first payment year for the incentive payment is CY 2011, which we believe should afford parties sufficient time to reach a new agreement. For Medicaid, a discussion of reassignment of the incentive payment is found in section II.D.3.e of this final rule ‘‘Entities Promoting the Adoption of Certified EHR technology.’’
DHS will administer the program consistent with the federal regulations. This assignment is a contract issue between you and your employer; it is inappropriate for DHS to be involved with this issue. We recommend you review your current contractual arrangements with your employer. You may need to discuss this with an attorney if you and your employer cannot come to an agreement.
When determining whether you are attesting to a group or clinic volume, or an individual volume, consider that MEIP defines an EHR incentive program attestation group as an MHCP enrolled group practice under a common tax identification number (TIN) and National Provider Identifier (NPI).
When determining your total Medicaid encounters for the MPV, DHS will count each global billing, or packaged services, encounter as a separate encounter. Global billing provided to the patient and not billed to DHS must be identified in your numerator and denominator results. See the MEIP Attestation Basics DHS-6667D (PDF) document in the MEIP website for more information on calculating MPV.
Access to MEIP requires a CMS confirmation number. The EPs can decide to complete the enrollment on their own or share their CMS confirmation number with the clinic administrative staff for the staff to act as a proxy. The name of the administrator can be entered in the attestation page to indicate a proxy was used.
It is the responsibility of the EPs to “control” their user account access in MEIP, which requires the CMS Confirmation Number. If the EPs provide someone with the information required to access their MEIP account, MEIP assumes that the EPs have delegated that authority accordingly.
The CMS Registration User Guide for Eligible Professionals (PDF) says “EPs may authorize surrogate users to work on behalf of the EP in the EHR Incentive Program Registration & Attestation system” and that you need to navigate to the Identity and Access Management (I&A) section to create a login account. The I&A section requires you enter the NPIs of the EPs you are representing. For more information on the CMS EHR process, see the CMS EHR Incentive Programs site.
An EP does not have to work a minimum number of hours to qualify. Patient volume is determined by a percentage of Medicaid patients, so theoretically, if an EP sees one Medicaid patient out of three total, the EP will qualify. The EP must meet all other eligibility requirements.
TIN is the taxpayer identification number, a unique identification number the IRS uses in the administration of tax law.
TIN types are taxpayer identification numbers classified as a Social Security number (SSN) or employer identification number (EIN) and are used as follows:
Page 16 of the CMS Registration guide clarifies where your payment will go in the payee TIN type:
When assigning payment during CMS registration, please ensure that:
The assigned payee information entered during this step is sent to MEIP. This choice can be changed only at the CMS registry level. The TIN or SSN provided during the CMS registration will be used for IRS purposes.
Once providers are enrolled, they need to attest each year they choose to participate if they want to continue to receive incentive payments. Providers may discontinue participation in the program at any point they choose, but if they decide to stop participation, they will receive no more payments through the EHR incentive program.
The MHCP provider affiliation file for the group is used to tie a set of EP Medicaid patient volume attestations together. The group updates group affiliation records by completing either the Individual Practitioner – MHCP Provider Profile Change Form DHS-3535 (PDF) or Organization – MHCP Provider Profile Change Form DHS-3535A (PDF) when an EP discontinues employment with the group.
Each EP must register at CMS’s EHR Incentive Program registration site before enrolling with MEIP. The MEIP group enrollment process is an EP all-in or EP all-out process. It is not a requirement that the EP was in the group for the period that is the basis for the proxy. EPs that are employed by the group after the group has attested are eligible as part of the group that year. The EP can choose to attest as an individual to the patient volume under a separate EHR system outside of the group.
No specific document is required. Refer to the following information about what is needed:
The screen shots from the American Board of Pediatrics (ABP) website and an upload of an EP’s license (although it does not mention the specialty) would generally be sufficient for the MEIP pediatrician documentation requirement. The Minnesota EHR incentive program team reserves the right to request additional supporting documentation if necessary. While a screen shot can be easily modified, a license is readily available and supports the ABP screen shot.
EP Jones may participate if he or she is part of a group and it is appropriate to include the encounters (that is, he or she sees Medicaid patients), even if he or she wasn’t in the group last year when the group patient volume proxy was calculated. The only caveat is if the group is an FQHC or RHC and using needy individual patient volume, the provider can only be added to the group proxy if the provider practiced predominantly at an FQHC or RHC for six months in the prior CY.
The Minnesota Medicaid EHR incentive program has applied for and been granted a grace period for attestation through CMS. As a result, the PY 2016 attestation deadline for EP, EH or CAH has been extended to April 29, 2017. We expect that all subsequent years will follow the standard 90-day grace period for attestation, so attestation must be complete by approximately March 29, 2018, and beyond.
Yes, psychiatrists enroll with MHCP under the physician provider type, which satisfies the Minnesota EHR incentive program (MEIP) provider type and enrollment with MHCP requirements.
The definition of a pediatrician for purposes of MEIP has been established in law. The statutory definition is listed in Minnesota Statutes 62J.495, Subd. 8 (f), and is as follows: “Pediatrician” means a physician who is certified by either the American Board of Pediatrics or the American Osteopathic Board of Pediatrics.
Only EPs who meet the Minnesota statutory definition of pediatrician in this section are allowed to qualify for the program at the 20 percent MPV threshold.
The MEIP defines an “out-of-state” encounter as any encounter that occurred (in Minnesota or outside of Minnesota) that was paid in full or part by another state’s Medicaid program. In considering whether to include out-of-state encounters in your Medicaid patient volume encounter data refer to the following:
The MEIP system does not require an EP to complete the enrollment during one login session. You can save an EP enrollment if you cannot complete the process and then return to it later. The enrollment of an EP Group is also a work in progress. The first member to complete a group patient volume establishes a group ID that other members can link to when they attest.
MHCP Provider Enrollment has up to 30 days to process these requests. MHCP does not contact the EP when the change is completed. The Provider Affiliations list is updated daily on the DHS provider portal, MN–ITS.
No, a hospital is allowed to complete the program once, regardless of changes to ownership.
A PA would be leading an FQHC, RHC, tribal or urban facility under any of the following circumstances:
FQHCs, RHCs and tribal or urban facilities that have PAs in these leadership roles can be considered ‘‘PA-led.’’ Furthermore, since RHCs can be practitioner owned (FQHCs cannot), we will allow ownership to be considered ‘‘PA-led.’’
See also http://www.gpo.gov/fdsys/pkg/FR-2010-07-28/pdf/2010-17207.pdf.
Individuals and FQHC, RHC, tribal or urban facility groups are not required to have malpractice insurance to enroll. However, if the provider does have it, MHCP Provider Enrollment will add this information to the provider’s record. For more information contact MHCP Provider Enrollment at 651-431-2700 or 800-366-5411; fax at 651-431-7462.
When you enroll for the MEIP, you will be asked if you practice predominantly (more than 50 percent during a six-month period) in an FQHC, RHC, tribal or urban facility and if so would select the FQHC, RHC, tribal or urban facility that employs you. EPs have the option to assign the incentive payment to the FQHC, RHC, tribal or urban facility or the EP if the EP has reported his or her SSN to MHCP Provider Enrollment.
Technically, the MEIP system will allow a “group of one” assuming the following occurs:
If the EP is enrolled as an individual and not a group practice with MHCP, MHCP Provider Enrollment staff would likely question why an individual is trying to create an affiliation group. If the EP is enrolled as a group with MHCP, many providers can be noted in the Affiliated Group list that are either not eligible or not participating in the EHR incentive program. It is important to remember when calculating patient volume, all Medicaid encounters that are seen at the group locations are included for every practitioner in the group or clinic, even those who are not eligible for the program, or those who are not participating. Do not include outside encounters in your group attestation. If the encounter (numerator/denominator) is outside the group, do not include it in the attestation.
When calculating patient volume, all Medicaid encounters that are seen at the group location are included for every practitioner in the group or clinic, even those who are not eligible for the program (such as, chiropractors), or those who are not participating. Do not include encounters that occur outside of the identified group location in your group attestation.
Providers may participate if they are part of a group and it is appropriate to include their encounters (that is, they see Medicaid patients), even if they weren’t in the group last year when the group patient volume proxy was calculated. The only caveat is if the group is an FQHC or RHC and using needy individual patient volume, the provider can be added to the group proxy only if the provider practiced predominantly at an FQHC or RHC for six months in the prior CY.
Yes, MEIP considers this an acceptable AIU supporting documentation. See CMS FAQ https://questions.cms.gov/faq.php?id=5005&faqId=5993.
If an EP, EH or CAH participating in the Medicare EHR incentive program chooses to change or withdraw its’ attestation, an attestation amendment form or incentive payment attestation withdrawal form must be completed and sent back along with any incentive payments already received. Use the following CMS forms:
Note that CMS does not require providers who relied on flawed software for their attestation information to submit amended attestation data. For additional information, see CMS FAQ#6097.
Yes, if you are eligible to participate in both the Medicare and Medicaid EHR incentive programs, you must demonstrate meaningful use according to the timelines to avoid the payment adjustments. You may demonstrate meaningful use under either Medicare or Medicaid. See the CMS Payment Adjustments & Hardship Information for the hardship exception application.
No, congress mandated that an EP must be a meaningful user to avoid the payment adjustment; therefore, receiving a Medicaid EHR incentive payment for adopting, implementing, or upgrading your certified EHR technology would not exempt you from the payment adjustments. You must demonstrate meaningful use according to the timelines to avoid the payment adjustments. You may demonstrate meaningful use under either Medicare or Medicaid. See the CMS Payment Adjustments & Hardship Information for the hardship exception application.
No, if you perform 90 percent or more of your covered professional services in either the inpatient or emergency department of a hospital, then you will be determined to be hospital-based and are not eligible to receive an EHR incentive and will not be subject to the payment adjustments.
However, your hospital-based status can change from year to year. For example, an EP who is determined to be hospital-based for the 2015 program year would not be subject to the payment adjustments in 2017. But if that EP is determined not to be hospital-based for the 2016 and the 2017 program year, then he or she could be subject to the payment adjustments in 2018 if the EP does not demonstrate meaningful use. Therefore, it is important to check your hospital-based status at the beginning of each year. You can check your hospital-based status by visiting the Medicare EHR Incentive Programs Registration System.
In the final rule issued on July 28, 2010, (page 44490) CMS clarified that:
After reviewing the federal definition of nurse practitioner services found in 42 CFR 440.166, Minnesota’s Medicaid State Plan, and scope of practice rules, DHS determined that clinical nurse specialists would meet the federal definition of nurse practitioner and are treated similarly in the Minnesota Medicaid State Plan and as such, were included in the State Medicaid HIT Plan (SMHP) as professionals who are potentially eligible for incentives under the Minnesota EHR incentive program. Minnesota’s SMHP was first approved by CMS on November 3, 2011.
Eligibility is not based on full-time or part-time work. The part-time EP must be an actively enrolled provider in good standing with MHCP and meet the same criteria as a full-time EP.
Here is a list of compatible browsers as of December 2015:
The portal does not support the latest Windows 10 browser, Edge.
A provider who has recently been employed by a group may participate as part of the group MPV if the provider actively sees Medicaid patients, even if they weren’t in the group last year when the group patient volume proxy was calculated.
Preparing and Maintaining Documentation
It is the provider’s responsibility to maintain documentation that fully supports MU and clinical quality measure data submitted during attestation. To ensure you are prepared for a potential audit, save any electronic or paper documentation that supports your attestation. Also, save the documentation that supports the values you entered in the Attestation Module for clinical quality measures. EHs should also maintain documentation that supports their payment calculations.
An audit may include a review of any of the documentation needed to support the information that was entered in the attestation. The level of the audit review may depend on a number of factors, and it is not possible to detail all supporting documents that may be requested as part of the audit. However, the following will outline the minimum supporting documentation that providers should maintain.
Source Document(s)
The primary documentation that will be requested in all reviews is the source document(s) that the provider used when completing the attestation. This document should provide a summary of the data that supports the information entered during attestation. Ideally, this would be a report from the certified EHR system, but other documentation may be used if a report is not available or the information entered differs from the report.
Providers should retain a report from the certified EHR system to validate all clinical quality measure data entered during attestation, since all clinical quality measure data must be reported directly from the certified EHR system.
Providers who use a source document other than a report from the certified EHR system to attest to meaningful use data (e.g., non-clinical quality measure data) should retain all documentation that demonstrates how the data was accumulated and calculated.
This primary document will be the starting point of most reviews and should include, at minimum:
Because some certified EHR systems are unable to generate reports that limit the calculation of measures to a prior time period, CMS suggests that providers download or print a copy of the report used at the time of attestation for their records.
Although the source document is the primary review step, there could be additional and more detailed reviews of any of the measures, including review of medical records and patient records. The provider should be able to provide documentation to support each measure to which he or she attested, including any exclusions claimed by the provider.
Source: CMS EHR Incentive Programs Supporting Documentation For Audits (PDF)
The MEIP portal has all active registries listed in the drop-down menus on the portal for attestation. If providers wish to attest to a registry that is not listed on the portal, they are directed to contact MEIP for verification of the registry. If MEIP is able to verify that a registry is active and accepting attestation, we will have it added to the portal as an option for future attestations. (Note: MEIP recommends that all EP, EH or CAH providers check with their professional or specialty organizations for alternate registries that may be available.)
Due to the specifications in the measure for this objective, because the summary of care document must be created using the CEHRT, it is then necessary for all providers to utilize the capabilities of the CEHRT to securely transmit the summary of care electronically to a receiving provider, and for this summary of care to be “consumable” at the other end. This excludes means of communication such as fax, unsecured email, etc.
At this point (PY 2015–2016), patient education via paper still counts towards attestation to this measure. Beginning with PY 2018, this information will need to be made available electronically to count towards attestation requirements. The measure as written states that this information must be made available to the patient. At this time, there is not a required percentage of patients that actually access the material. Providing the information in a format appropriate for your particular patient is still expected and part of quality care.
Yes, you may take an exclusion to this measure, but you must either meet this measure or exclude it from the other qualified registries for this measure for the public health reporting objective. For example, a Stage 1 EP may take the exclusion for syndromic surveillance, as well as an exclusion for specialized registry reporting, but if the EP is eligible and able to register and report with an immunization data registry, then it is the providers’ responsibility to attest using that registry. If a provider is eligible and qualifies for exclusion to all available registries, then the provider may take the exclusion to the public health registry reporting objective.
The Modified Stage 2 Final Rule states that providers may demonstrate “active engagement” in one of the following three ways:
From the Centers for Disease Control and Prevention (CDC): “The MU Stage 2 regulations are purposefully general in describing specialized registries to provide flexibility and avoid excluding registries.” Refer to the following information about specialized registries:
An ACO forming its own specialized registry would be at odds or at least not congruent with the goals of a specialized registry. It would also make more sense to join a national or state registry in a specialty area rather than forming a new regional registry.
Starting in 2013, an EP must meet the threshold of 50 percent of patient encounters at locations equipped with certified EHR technology to be eligible for the EHR Incentive Program. If the EP meets this threshold and also includes information on patient encounters at locations where they do not have access to certified EHR technology, information about those encounters can be included when calculating the numerators and denominators for the meaningful use measures.
For eligible professionals who participate in MEIP, there are a total of 10 MU objectives (nine for EH). Certain objectives provide exclusions (and alternate exclusions if you are in stage 1). If an EP meets the criteria for exclusion, then the EP can claim that exclusion during attestation. However, if an exclusion is not provided, or if the EP does not meet the criteria for an existing exclusion, then the EP must meet the measure of the objective to successfully demonstrate meaningful use and receive an EHR incentive payment. 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.
Beginning with PY 2015, the Stage 2 Final Rule synchronizes the attestation program year for all providers. EHs, CAHs, and EPs will be aligned with the calendar year. For PY 2015 only, EHs can select an MU reporting period using any 90-day period between Oct. 1, 2014, and Dec. 31, 2015. Starting 2016, the EH and CAH MU reporting period must be entirely within the calendar year, Jan. 1, 2016 through Dec. 31, 2016.
NOTE: All PY 2016 EP will be required to use an MU EHR reporting period of 90 days. Beginning in PY 2017, providers attesting to MU will use a 90-day reporting period for MU and a 365-day reporting period for CQM.
In this case, EPs should base both the numerators and denominators for meaningful use objectives on the number of unique patients in the outpatient setting, since this setting is where they are eligible to receive payments from the Medicare and Medicaid EHR incentive programs.
For more information, please see CMS FAQ#2765.
No, there are objectives for which no exclusions are available, but providers may take as many exclusions or alternate exclusions as they qualify for.
No, this exclusion applies only to measure 2 for this objective. Measure 1 is making the ability to access records electronically available, which is not impacted by internet speed in your area. This applies to the exclusion for both EP and EH or CAH.
