Fall QClC - Meaningful Use 2011 – The Countdown Begins!

 

Eligible Providers across the state are preparing to attest to Meaningful Use objectives in order to receive 2011 incentive payments through the Federal government’s HITECH program.  Following are the basics on eligibility, timelines and steps that you can take right now to begin the path forward to demonstrating effective use of Health Information Technology to qualify for federal incentives.  Much of this information is pulled from the CMS EHR Incentive Program website and support center:  http://www.cms.gov/ehrincentiveprograms/

1. Are you eligible?

Differences Between the Medicare and Medicaid EHR Incentive Programs

With the exception of dually-eligible hospitals, providers can only participate in one of the EHR Incentive Programs – Medicare or Medicaid – each year:

For the Medicare EHR Incentive Program, eligible participants include:

-  Doctors of medicine or osteopathy
-  Doctors of dental surgery or dental medicine
-  Doctors of podiatry
-  Doctors of optometry
-  Chiropractors
- "Subsection (d) hospitals" in the 50 states or DC that are paid under the Inpatient Prospective Payment System (IPPS)
-  Critical Access Hospitals (CAHs)
-  Medicare Advantage (MA-Affiliated) Hospitals

 

For the Medicaid EHR Incentive Program, eligible participants include:

-  Physicians (primarily doctors of medicine and doctors of osteopathy)

-  Nurse practitioners

-  Certified nurse-midwives

-  Dentists

-  Physician assistants who furnish services in a Federally-Qualified Health Center or Rural Health Clinic that is led by a physician assistant

-  Acute care hospitals (including CAHs and cancer hospitals) with at least 10% Medicaid patient volume

-  Children’s hospitals (no Medicaid patient volume requirements)

 

Not sure which program to choose? Compare "Notable Differences between the Medicare and Medicaid EHR Incentive Programs" .

Dually-Eligible Hospitals: If you represent a hospital that meets all of the following qualifications, you are dually-eligible for the Medicare and Medicaid EHR Incentive Programs:

-   You are a subsection (d) hospital in the 50 states or DC, or you are a CAH; and

-   You have a CMS Certification Number ending in 0001-0879 or 1300-1399; and

-  You have 10% of your patient volume derived from Medicaid encounters.

 

2. If you are an Eligible Provider, Register with CMS Now!

In order to make sure that you are able to meet the required attestation periods, and to avoid payment delays, register with CMS as soon as possible.  You can register before you have a certified EHR. Register even if you do not have an enrollment record in PECOS which is required for all hospitals and Medicare eligible professionals.  Please access the CMS EHR Incentive Registration Guides for step-by-step instructions:

• Medicare Eligible Providers
• Medicaid Eligible Providers
• Eligible Hospitals

To expedite Registration, Make sure you have enrollment records in the appropriate systems. You’ll need:

• A National Provider Identifier (NPI)
  • All eligible professionals, eligible hospitals, and critical access hospitals (CAHs) must have a National Provider Identifier (NPI) to participate in the Medicare and Medicaid EHR Incentive Programs.
• An enrollment record in the Provider Enrollment, Chain and Ownership System (PECOS)
  • All eligible hospitals and Medicare eligible professionals must have an enrollment record in PECOS to participate in the EHR Incentive Programs. (Note: Eligible professionals who are only participating in the Medicaid EHR Incentive Program are not required to be enrolled in PECOS.)
  • If you do not have an enrollment record in PECOS, you should still register for the Medicare and Medicaid EHR Incentive Programs.

CMS Identity and Access Management (I&A) User ID and Password:

• Eligible Professionals:
  • Eligible professionals can use the same User ID and Password they use for the National Plan and Provider Enumeration System (NPPES). This is also the same User ID and Password that is used to access PECOS.
  • If you are an EP who does not have an NPI and/or an NPPES web user account, go to NPPES to apply for an NPI and/or create an NPPES web user account.
• Hospitals/Critical Access Hospitals:
  • Authorized Officials can use the same User ID and Password they use to access PECOS.
  • If you do not have an Authorized Official with access to PECOS, request a User ID and Password via Identity & Access Management. You will need your type 2 NPI, your Taxpayer Identification Number (TIN), and your address from the IRS Form CP-575. You will need to mail a copy of the IRS Form CP-575 as directed.
  • Additional hospital staff will need to request access to the "EHR Incentive Programs" application through Identity & Access Management and be approved by the Hospital’s Authorized Official.

3. Make sure you are using CMS certified Electronic Health Record technology.

The Medicare and Medicaid EHR Incentive Programs require the use of certified EHR technology. Standards, implementation specifications, and certification criteria for EHR technology have been adopted by the Secretary of the Department of Health and Human Services. EHR technology must be tested and certified by an Office of the National Coordinator (ONC) Authorized Testing and Certification Body (ATCB) in order for a provider to qualify for EHR incentive payments.

IMPORTANT: Even if you are already using EHR technology, it must be tested and certified by an ONC-ATCB specifically for the Medicare and Medicaid EHR Incentive Programs.

Where to find Certified EHR Technology for the Medicare and Medicaid EHR Incentive Programs

EHR technologies that meet the certification requirements for the Medicare and Medicaid EHR Incentive Programs are listed on the ONC Web site: http://onc-chpl.force.com/ehrcert

REMEMBER: You do not need to have your certified EHR technology in place to register for the EHR incentive programs! However, you must adopt, implement, upgrade, or successfully demonstrate meaningful use of certified EHR technology under the Medicaid EHR Incentive Program and successfully demonstrate meaningful use of certified EHR technology under the Medicare EHR Incentive Program before you can receive an EHR incentive payment.

4. Determine where you are in the Meaningful Use Timeline.

Medicare Eligible Providers: You have to successfully demonstrate "meaningful use" for a consecutive 90-day period in your first year of participation (and for a full year in each subsequent years) to receive EHR incentive payments. The final deadline to begin this 90-day period in order to qualify for the 2011 incentive payments was October 1, 2011.  Visit the CMS Meaningful Use webpage.

Medicaid Eligible Providers: If you're an eligible professional, in your first year of participation you may adopt, implement or upgrade or become a meaningful user of certified electronic health records to qualify for incentive payments.  To receive EHR incentive payments in the first year under the Medicaid EHR Incentive Program, you must do at least one of the following:

• Adopt certified EHR technology; or
• Implement certified EHR technology you have already purchased; or
• Upgrade your current EHR technology to the newly certified version; or
• Demonstrate "meaningful use" of certified EHR technology for a 90-day period. The final deadline to begin this 90-day period in order to qualify for the 2011 incentive payments was October 1, 2011.

Visit Maine's Medicaid agency Web site:   http://www.maine.gov/dhhs/oms/HIT/index.html or the CMS  Meaningful Use webpage to learn about meaningful use objectives and measures.

5. If you’re ready – Attest!

Medicare Eligible Providers: To get your EHR incentive payment, you must attest (legally state) through Medicare's secure Web site that you've demonstrated "meaningful use" with certified EHR technology. You can now get to our secure Attestation Web site through a link at the CMS Attestation page .

Medicaid Eligible Providers: To get your EHR incentive payment, you must attest (legally state) through your state's Medicaid agency Web site that you've met all of the eligibility criteria, including having adopted, implemented, upgraded or meaningfully used certified EHR technology. Visit Maine’s Medicaid agency Web site: http://www.maine.gov/dhhs/oms/HIT/index.html for more information.