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I Need Help with Meaningful Use
- Meaningful Use Resources
- Frequently Asked Questions for Meaningful Use
- Registration & Attestation
- Frequently Asked Questions for Maryland Medicaid
- State-Regulated Payor EHR Adoption Incentive Program
The Medicare and Medicaid EHR Incentive Programs provide a financial incentive for the "meaningful use" of certified EHR technology to achieve health and efficiency goals. By putting into action and meaningfully using an EHR system, providers will reap benefits beyond financial incentives–such as reduction in errors, availability of records and data, reminders and alerts, clinical decision support, and e-prescribing/refill automation. Here, you will find resources with more information as well as a CMS EHR Meaningful Use Criteria Summary.
For more information, please visit CMS' official EHR Incentive Programs Page by clicking on the logo below.
Click here to learn more about Maryland's EHR Incentive Program.
Finding the right answer to your meaningful use questions can be tricky. CRISP feels that it is in the best interest of providers to go directly to the CMS website to search for your answer. CMS has an intuitive Frequently Asked Questions (FAQ) section - just type in a few key words and click search. If you still cannot locate an answer to your questions, please email us at rec@crisphealth.org and we can assist you.
Click here to access CMS Frequently Asked Questions (FAQ)
CRISP also recommends subscribing mailing list to receive important EHR and other CMS incentive program updates via email as soon as they come out.
Click here to subscribe to the CMS email updates
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The American Recovery and Reinvestment Act of 2009 specifies three main components of Meaningful Use:
- The use of a certified EHR in a meaningful manner, such as e-prescribing.
- The use of certified EHR technology for electronic exchange of health information to improve quality of health care.
- The use of certified EHR technology to submit clinical quality and other measures.
Simply put, "meaningful use" means providers need to show they're using certified EHR technology in ways that can be measured significantly in quality and in quantity.
Click here to learn more on the CMS website.
Meaningful use includes both a core set and a menu set of objectives that are specific to eligible professionals or eligible hospitals and CAHs. For eligible professionals, there are a total of 25 meaningful use objectives. To qualify for an incentive payment, 20 of these 25 objectives must be met.
- There are 15 required core objectives.
- The remaining 5 objectives may be chosen from the list of 10 menu set objectives.
For eligible hospitals and CAHs, there are a total of 24 meaningful use objectives. To qualify for an incentive payment, 19 of these 24 objectives must be met.
- There are 14 required core objectives.
- The remaining 5 objectives may be chosen from the list of 10 menu set objectives.
Click here to access the specific core and menu set measures.
Stage 1 "Meaningful Use" criteria, beginning in 2011, are focused upon the electronic capture of medical information in a fully-coded format and the use of that information to track clinical conditions and for the purpose of assisting with care coordination. Stage 1 also proposes the use of clinical decision support applications to facilitate disease and medication management and requires the reporting of clinical quality metrics and public health information.
For 2011, CMS has outlined 25 specific Meaningful Use objectives and associated performance measures for eligible physicians. In 2012, CMS will also require the direct electronic submission of clinical quality measures to CMS via certified EHR technology.
Stage 2 criteria will be based upon the findings of Stage 1 and are expected to leverage the broader use of the EHR technology implemented during 2011 and 2012. Stage 2 will bring greater emphasis on disease management, clinical decision support, medication management, patient access to personal health information, care transition of care, and bi-directional communication between physicians and public health agencies.
Stage 3 will be centered on improvements in quality, safety and efficiency; will require clinical decision support for conditions of high-priority to the general public health; and provide patient access to health self-management tools.
As outlined in the table above, the Medicare incentive program is designed to promote early adoption and ongoing utilization of a qualified EHR. There are also significant penalties for delaying adoption. Missing out on the ARRA incentive payments is one thing, but physicians who have not achieved Meaningful EHR use by 2015 will see their Medicare fee schedule amount reduced by 1% in 2015, by 2% in 2016, by 3% for 2017 and by between 3-5% in subsequent years if less than75% of providers have not yet adopted EHRs.
As with the Medicare incentives, the Medicaid incentive program is designed to promote rapid adoption of EHRs. The payments of $21,250 are designed to cover the cost of procuring or upgrading an EHR & related hardware. Subsequent $8,500 payments are contingent on achieving and maintaining meaningful use. Federal funds may not be used for Medicaid incentive payments for the purchase of EHR technology after 2016 or for the maintenance of EMRs after 2021. Unlike Medicare, the Medicaid EHR adoption program does not have payment penalties after the incentive payment period end. The Medicare and Medicaid programs differ here. For Medicaid, an eligible professional can receive an incentive payment for Acquiring, Implementing or Upgrading a certified EHR product in their first year. In the first year of adoption, a physician must be use a certified EHR in a manner consistent with the Meaningful Use criteria for a minimum of 90 days in order to qualify for incentives. In subsequent years, the EHR must be used in a meaningful manner for the entire year.
Registration:
We encourage providers to register for the Medicare and/or Medicaid EHR Incentive Program(s) as soon as possible to avoid payment delays. Please note that not all states have launched a Medicaid EHR Incentive Program yet. CMS has published an EHR Incentive Program Registration User Guide that can walk providers through the registration process.
If you are ready, click here to register for the CMS EHR Incentive Program.
Attestation:
Medicare eligible professionals will have to demonstrate meaningful use through CMS' web-based Registration and Attestation System. In the Medicare & Medicaid EHR Incentive Program Registration and Attestation System, providers will fill in numerators and denominators for the meaningful use objectives and clinical quality measures, indicate if they qualify for exclusions to specific objectives, and legally attest that they have successfully demonstrated meaningful use. Click here to learn more about the attestation process.
Want to practice attesting? Click here to access the CMS Meaningful Use Attestation Calculator
General
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Maryland’s Regional Extension Center (REC) provides support to providers interested in adopting EHRs. Our REC is CRISP, the same entity charged with developing the statewide Health Information Exchange (HIE). For help in choosing and adopting an EHR, visit CRISP at http://www.crisphealth.org/. You may also be interested in visiting the Maryland Health Care Commission’s (MHCC) EHR Product Portfolio, an online repository of individual and comparative EHR product and vendor information. The EHR Product Portfolio is located at http://mhcc.maryland.gov/electronichealth/ehr/ehrvendors.html. Maryland will only accept attestation for adopting, implementing or upgrading (A,I,U) certified EHR technology in the first year that a provider participates in the program. There is no time period for attestation for A,I,U; however, the State’s registration and attestation may ask for you to select a 90-day attestation period. In the second year of participation (first year of “meaningful use”), a provider must attest to meeting the meaningful use criteria for any continuous 90 day period within the same payment year. With the Medicaid EHR Incentive Program, each Eligible Professional (EP) would receive an incentive payment. Medical Assistance EPs can reassign their incentive payments to one entity such as his or her employer or an entity which they have a valid employment agreement or valid contractual arrangement that allows the entity to bill for the EP's services. Applicants will attest to this relationship during the application process.
Maryland will allow providers to select a pay-to provider based on the current financial relationships established with the Department of Health and Mental Hygiene (DHMH). If you are unsure of the pay-to provider relationships you currently have with DHMH or if you would like to add another pay-to provider or group to your existing NPI, please contact provider enrollment at 410-767-5340.
You may find a list of certified EHR programs on the Office of the National Coordinator for Health Information Technology (ONC) website. Here is the web address: http://onc-chpl.force.com/ehrcert. If you already have an EHR system, you should contact your vendor to enquire about its certification status. In order to qualify for the AIU part of the EHR Incentive Program, you would need to attest to one of the following: 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; or Upgrade: expanding the available functionality of certified EHR technology capable of meeting meaningful use requirements at the practice site, including staffing, maintenance, and training, or upgrade from existing EHR technology to certified EHR technology per the EHR certification criteria published by the Office of the National Coordinator of Health Information Technology (ONC). Thus, a signed contract indicating that the provider has adopted or upgraded would be sufficient.
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Patient Volume
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Hospital-based is determined by the site where the service was delivered. Physicians who furnish substantially all, defined as 90 percent or more, of their Medicaid covered professional services in either an inpatient (POS 21) or emergency department (POS 23) of a hospital are considered to be hospital-based and are therefore not eligible for incentive payments under the Medicaid EHR Incentive Programs.
Yes, even though individual Eligible Professionals (EPs) can use the group MA patient volume methodology to qualify for the EHR Incentive Program, payments are made to individual EPs. If these EPs qualify under the group calculation then each would receive the incentive payment. For example, if in Year 1 the group successfully A,I,Us, and the practice volume meets the patient volume threshold for the eligible providers in the practice, then each provider would receive an incentive payment of $21,250.
Providers may use the group proxy patient volume under these conditions:
(1) The clinic or group practice's patient volume is appropriate as a patient volume methodology calculation for the EP (for example, if an EP only sees Medicare, commercial, or self-pay patients, this is not an appropriate calculation);
(2) there is an auditable data source to support the clinic's patient volume determination; and
(3) so long as the practice and EPs decide to use one methodology in each year (in other words, clinics could not have some of the EPs using their individual patient volume for patients seen at the clinic, while others use the clinic-level data). The clinic or practice must use the entire practice's patient volume and not limit it in any way. EPs may attest to patient volume under the individual calculation or the group/clinic proxy in any participation year. Furthermore, if the EP works in both the clinic and outside the clinic (or with and outside a group practice), then the clinic/practice level determination includes only those encounters associated with the clinic/practice.
Patient volume is based on a continuous and representative 90-day period in the previous calendar year for eligible providers (EP) and a continuous and representative 90-day period in the previous fiscal year for eligible hospitals (EH). Maryland will accept all Fee-for-Service and Managed Care encounters where:
1. Medicaid is the secondary and Medicare is the primary payer;
2. The beneficiary is enrolled in any Medicaid program BUT a Children’s Health Insurance Program (CHIP) program. In Maryland, the CHIP programs are Maryland Children’s Health Program (MCHP) and Maryland Children’s Health Program (MCHP) Premium.
Because many providers cannot distinguish between MCHP patients and other Medicaid patients, the Department will be applying a standard deduction.
Yes, the Medicaid MCO’s count toward the patient volume threshold. However, keep in mind that because of the CHIP exclusion, an eligible provider with a 30% patient volume requirement would actually have to meet a 38% patient volume requirement.
Yes, we will have access to both behavioral health and dental claims data to verify patient volume.
The final CMS ruling regarding children’s hospitals states that: a children’s hospital is exempt from meeting the patient volume threshold. Thus, all Children’s Hospitals can participate in the program.
No, there is no minimum number of MA individuals or encounters, but you must meet the threshold volume for all sites.
Yes, if the encounter with the dual-eligible patient meets the definition of encounter. For purposes of calculating EP patient volume, a Medicaid encounter means services rendered to an individual on any one day where Medicaid paid for part or all of the service; or paid all or part of the individual’s premiums, copayments, and cost-sharing.
Yes, MA patient volume includes MA Managed Care encounters. For purposes of calculating EP patient volume, a Medicaid encounter means services rendered to an individual on any one day where Medicaid paid for part or all of the service; or paid all or part of the individual’s premiums, copayments, and cost-sharing.
Yes. Please be prepared to submit documentation from an auditable data source such as practice management output to the State when you attest.
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Part-Time/Contractual/Group Calculation
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In using the group calculation the practice and EPs must decide to use one methodology in each year (in other words, clinics could not have some of the EPs using their individual patient volume for patients seen at the clinic, while others use the clinic-level data). The clinic or practice must use the entire practice's patient volume (including part-time providers) and not limit it in any way. You may use multiple locations but will need to use the group NPI number.
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CMS Registration
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Someone can apply on behalf of the Eligible Professional in Maryland’s Registration and Attestation System. However, the eligible professional must still legally attest they meet requirements for receiving payments.
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Hospitals
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Eligible hospitals for the Medicaid EHR Incentive program in Maryland include acute care, critical access, and children’s hospitals. Hospitals are eligible for both Medical Assistance and Medicare EHR incentive payments except for children’s hospitals and cancer hospitals which are only eligible for Medical Assistance incentive payments. There are specific sets of CMS Certification Numbers (CCN) that correspond to eligible hospitals: CCNs with the 0001 – 0879 (acute care), 1300-1399 (critical access hospitals), or 3300-3399 (children’s hospitals) as the last four digits in the series. If you fit into one of these categories, you would begin your registration through the same process as an Eligible Professional. The Department is working with the Health Services Cost Review Commission (HSCRC) to calculate incentive payments for eligible hospitals. The worksheet used to calculate incentives will be shared with hospitals before they register and attest with the State. The Department will compare hospital calculated incentive payments using the worksheet with our own calculations and work out any discrepancies before registration and attestation.
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Provider Eligibility
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Not all providers within a practice must participate in the same incentive program. If they are eligible, some could participate in the Medicare EHR Incentive Program and some could participate in the Medicaid EHR Incentive Program.
A Physician Assistant is eligible only if he/she is participating in a FQHC that is so led by a PA. This would be when a PA is the primary provider in a clinic, when a PA is a clinical or medical director at a clinical site of practice.
Yes. However, you must be enrolled as a Maryland Medicaid provider. If you are not sure if you are enrolled, please contact provider enrollment at 410-767-5340. Also, be prepared to submit documentation about your Medicaid patient volume from an auditable data source when you register and attest with Maryland.
Yes. EPs and EHs will have to re-attest to meeting patient volume qualifications each year they participate in the program.
Because of the CHIP exclusion, pediatricians must meet a 28% Medicaid patient volume threshold and physicians must meet a 38% patient volume threshold. If the pediatrician has at least a 38% Medicaid patient volume, they can participate in the Maryland Medicaid EHR Incentive Program as a physician.
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Application, Enrolling, Attestation
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Yes, all EPs apply for incentive payments individually but can attest to MA patient volume using either the individual or group MA patient volume methodology.
Once your application is approved, it will take approximately two to three weeks to receive payment.
Yes, an Eligible Professional (EP) may skip more than one year and they do not need to be consecutive years. A provider may decide to attest to AIU in year one and then they may not be quite ready in year two to attest to 90 days of meaningful use. A provider may also change their place of employment and may go to an office that is not quite ready to participate in the program so they could wait until that office is ready to participate.
The Eligible Professional (EP) is considered the applicant, but they can designate someone on their behalf to complete the attestations. However, the eligible professional must still legally attest they meet requirements for receiving payments.
At any time during Year One, a provider can demonstrate that they have adopted, implemented, or upgraded to an EHR system. During State registration and attestation, you will be asked to select a 90-day attestation period for A,I,U.
Yes, Maryland Medicaid will have an attestation tail for both eligible providers and eligible hospitals. An attestation tail is a period after which the registration and attestation period has ended, but during which a provider or hospital can still register, attest, and receive an incentive payment for the previous year. For both eligible providers and eligible hospitals, a 90-day registration and attestation tail will be added on to the end of the registration and attestation period.
This means that for Federal fiscal year 2011, eligible hospitals will have until December 31, 2011 to register and attest with Maryland to receive a year 1 incentive payment for Federal fiscal year 2011.
For calendar year 2011, providers will have until March 31, 2012 to register and attest with Maryland to receive a year 1 incentive payment for calendar year 2011.
Although Maryland will always provide for an attestation tail for eligible providers and hospitals in future years, Maryland may decide to reduce this period.
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The State- Regulated Payor EHR Adoption Incentive Application (application) requests an estimate of the number of patients assigned by the payor to the practice at the time of the application. The State- Regulated Payor EHR Adoption Payment Request From (payment form) requests a listing of these patients at the time of the payment request. Each payor will determine if they will send the practice the estimated number or generate a list of these patients per practice. We recommend you contact the payor to determine their method. Contact information is available on both the application and payment form and is available here: http://mhcc.maryland.gov/electronichealth/stateincentive/stateehrincentive.htmlThe base incentive is calculated at $8 per member and is limited to the payor’s patient members who are Maryland residents. If the patient is self-insured or fully insured they will be included. The regulation states that the incentives are available for primary care practices, but it does not stipulate further guidance about the practice location. Since the incentives are calculated per member, they are based on the number of patients assigned to that practice rather than the number of locations. Each payor might determine the location differently. Some payors might decide to use tax identification numbers and others may choose to use the physical address of the location. The MHCC encourages you to contact the payors that you are doing business with to determine their policies. Contact information is available here:
http://mhcc.maryland.gov/electronichealth/stateincentive/stateehrincentive.html
The regulation states the incentive program applies to state-regulated payors, which include Aetna, CareFirst, Cigna, Coventry, Kaiser Permanente, and United Healthcare. If any of these payor insure commercial, Medicare, or Medicaid patients then those patients should be included in the incentive calculation. Yes, see answer to question four above. The regulation does not give the MHCC or CRISP authority to instruct payors in this way. The MHCC encourages you to contact the payors that you are doing business with to determine their policies. Currently, the regulation stipulates primary care practices only; however, there may be opportunity in the future to expand the eligible specialties. In particular, House Bill 736, Electronic Health Records –Incentive for Health Care Providers – Regulation, requires the MHCC, in consultation with the Department of Health and Mental Hygiene, payors, and health care providers to study whether to expand eligibility and report to the Governor and the General Assembly on or before January 1, 2013. There are three additional incentive components, including advance use of an EHR as determined by the payor. Currently the payors have not provided information to the MHCC regarding how they will determine a practice has demonstrated advance use. The MHCC encourages you to contact the payors that you are doing business with to determine their policies. Contact information is available here:
http://mhcc.maryland.gov/electronichealth/stateincentive/stateehrincentive.html
Potentially, yes. If you have patients with five of the state-regulated payors, have the maximum amount of patient panel members within your practice with each of those payors (about 938 patients per payor), and you meet at least one of the additional incentive components for each of the payors, you could receive a total amount of $75,000. The State-Regulated Payor EHR Incentives are available to practices not individual providers. The regulations stipulate that only primary care practices qualify for the EHR adoption incentives. This is defined as a medical practice located in the State that is comprised of one or more physicians who provide medical care in family, general, geriatric, internal medicine, pediatric, or gynecologic practice. Each payor have provided us with contact information, which is included here:
If payors establish a webpage specific to the EHR adoption incentives, we will include that within our list. At this time we have not been provided with information regarding any payor webpage specific the EHR adoption incentives.
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CHESAPEAKE REGIONAL INFORMATION SYSTEM FOR OUR PATIENTS
CRISP · 7160 Columbia Gateway Drive, Suite 230 · Columbia,
Maryland 21046
T/877-95-CRISP (27477) · F/443-817-9587 · info@crisphealth.org
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