Under a subaward or contract under a grant, the prior-approval authority usually is the prime-recipient (the REC). However, the recipient may not approve any action or cost that is inconsistent with the purpose or terms and conditions of the HHS grant. If an action by a subrecipient or contractor will result in a change in the project/program scope or budget, the recipient (the REC) must obtain prior approval from ONC before giving its approval to the subrecipient or contractor.

All contracts require prior approval from ONC. Funds may not be used until the following 6 points of required information for each contract is submitted to and approved by ONC. It is recommended that RECs submit the actual contract as well to assist in and expedite the approval process. 

1. Name of Contractor:  Who is the contractor?  Identify the name of the proposed contractor and Indicate whether the contract is with an Institution or organization.
2. Method of Selection:  How was the contractor selected?  State whether the contract is sole source or competitive bid.  If an organization is the sole source for the contract, include an explanation as to why this institution is the only able to perform contract services.
3. Period of Performance:  How long is the contract period?  Specify the beginning and ending dates of the contract.
4. Scope of Work:  What will the contractor do?  Describe in outcome terms, the specific services/tasks to be performed by the contractor as related to the accomplishment of program objectives. Deliverables should be clearly defined.
5. Method of Accountability: How will the contractor be monitored?  Describe how the progress and performance of the contractor will be monitored during and on close of the contract period.  Identify who will be responsible for supervising the contract.
6. Itemized budget and justification:  Provide an itemized budget with appropriate justification.  If applicable, include any indirect cost paid under the contract and indirect cost used.  Provide a copy of the negotiated indirect cost rate agreement.

There is no deadline for the application with the MHCC; however, we encourage you to submit your application soon to take advantage of the limited direct assistance funds from the ONC.

No. The MHCC State Designation process will be open to organizations indefinitely. The MHCC seeks to create a vibrant marketplace for MSOs to compete and do business throughout Maryland.

No.  However, the $4 million in direct assistance funding is finite and will be distributed on a “first come, first served” basis as MSOs reach their milestones.

It is up to each organization to determine where the MSO will reside within their organization.

Yes. The funding restrictions are defined in the funding opportunity announcement (FOA) located on the ONC website, but in general funds cannot be spent on hardware or software licenses.

The funds are available on a “first come, first served” basis. CRISP will be closely monitoring the spending and will apply to receive more direct assistance funding based on projections.

While ONC recognizes that some pharmacies do not have the ability to receive true electronic prescriptions, the EHR that the provider is using must have EDI capability enabled. 

To meet the quality reporting portion of Milestone 2, a practice may extract data from the Electronic Health Record for any of the following uses (list is not exhaustive): 

1. a public health department (such as a disease or immunization registry)
2. the Physician Quality and Reporting Initiative (PQRI)
3. a lab data report generated from the EHR

ONC will accept attestation from the REC that a practice has met the go-live requirements. The REC should establish and consistently maintain their procedures for verification that ePrescribing and Quality Reporting has occurred for each practice. The REC should maintain consistent records of the verifications for use in annual audits and site visits by ONC grants and program staff.

There are four main criteria to include in your agreement:

• Applicable descriptive and demographic information should be included.
• The agreement should outline the practice’s and associated providers’ intention to work towards meaningful use and include a stated understanding of what that entails.
• The agreement should outline the MSO's role, responsibilities, and contributions to the process of reaching meaningful use, as defined in the contract between the MSO and CRISP.
• The agreement should specify a timeline; agreements must not be open-ended.

• The name and version of the EHR that the provider is using
• The date they entered into an agreement to use the system
• The date they went live on the system
• The date the provider used the system to ePrescribe
• The date the provider used the system to generate a quality report

Yes, you may “over-recruit” providers. However, please consider the risk that the direct assistance funds may be exhausted prior to getting targeted PPCPs to meaningful use.

ONC will accept the form of agreement that is standard to the REC’s business practices and is consistent with applicable federal and state statutes. Keep in mind that all RECs should maintain a consistent file system (soft or hard copy) for storing provider agreements for the purposes of annual audits and site visits by ONC grants and program staff.

As outlined by the ONC, a priority primary care provider is a licensed clinician with prescriptive privileges (MD, DO, NP, PA) that works in the following practice care settings:

• Private physician practice of 10 or less
• Non-profit primary care clinics including community health centers and rural health clinics
• The ambulatory care clinics associated with public, rural, and critical access hospitals.

PPCPs must be certified in Internal Medicine, Family Practice, Pediatrics, Geriatrics, OB/GYN, and Adolescent Medicine.

The Provider Payment Cap for federal subsidy for Regional Center’s now states direct technical assistance to any single site or specific geographic location will be capped at the amount allocated for a practice equal to or less than ten priority primary care providers.  Prior Provider Payment Cap for direct assistant funding was allocated to any single incorporated or tax ID for a practice equal to or less than ten priority primary care providers.

This change is a result of the ONC recognizing that many of the priority primary care settings, such as federally qualified health centers and public hospitals, operate multiple sites, each of which operates essentially in the same way as a small provider office. Each site may serve a different population and therefore have different workflow/training needs which will need to be addressed if the providers are to achieve meaningful use. 

Yes, as long as they meet the definition of a PPCP and are fewer than ten, they are eligible.

A participating Priority Primary Care Provider must have prescription privileges to be eligible for reimbursement through the REC program. ONC does not require proof of the frequency in which a provider writes prescriptions nor specifies a required drug schedule that a provider must have privileges for. For ONC reimbursement purposes, the provider must be a licensed professional with prescription privileges as specified by their state for their license type.

CRISP is working with the ONC to further define this policy.

Yes; however, PPCPs cannot be double-counted if they practice at multiple groups. They can only be counted under one group (unique tax ID #).

No, PPCPs must be licensed and must have prescriptive privileges.

Because the Provider Payment Cap now states that the federal subsidy can be received for up to ten PPCPs per single site or specific geographic location, FQHCs can receive funds for up to ten PPCPs in each of their sites.