- 1 What Exactly is Meaningful Use/Promoting Interoperability?
- 2 Who is Eligible to Participate?
- 3 When Can I Attest?
- 4 What Must I Do to Qualify for Funds from the Medicaid EHR Incentive Program?
- 5 How Much Money Can My Practice Receive From the Medicaid EHR Incentive Program?
- 6 Will I Get Audited?
- 7 What Else Do I Need to Know?
As part of the American Recovery and Reinvestment Act of 2009 (ARRA), the Centers for Medicare & Medicaid Services (CMS) created the EHR Incentive Program. This program began in 2011, and was referred to as “Meaningful Use” until 2018, when the program name changed to “Promoting Interoperability”. The intent of the new name is to focus more clearly on the exchange of clinical data.
PCC practices that use PCC EHR can participate in the Medicaid EHR Incentive Program.
What Exactly is Meaningful Use/Promoting Interoperability?
The best summary of what the Medicaid Meaningful Use program does is found on CMS.gov:
“The Medicaid EHR Incentive Program provides incentive payments to eligible professionals, eligible hospitals, and critical access hospitals as they adopt, implement, upgrade, or demonstrate meaningful use of certified EHR technology. To receive the incentive payments, providers must show that they are meeting a number of objectives and demonstrating meaningful use of their EHRs. There are no penalties for not participating in the Medicaid EHR Incentive Program.”
Every state runs their own Medicaid program. Meaningful Use applications are filed through your state, and the deadlines can vary. Many states provide Regional Extension Centers (RECs) that can assist providers with their state’s requirements.
As it stands right now, 2017 is the last year to start participating in Meaningful Use. There are no Medicaid payment reductions if you choose not to participate.
You can learn more about the program at CMS.gov’s EHR Incentive Programs page.
When the program was first established, it was anticipated that there would be three stages of Meaningful Use. In Stage 1, providers would adopt an EHR and begin gathering data. Stage 2 emphasized care coordination and the electronic exchange of clinical patient data. Stage 3 was expected to focus on improving healthcare outcomes. Providers would remain in each stage for one or two years, depending on their year of adoption and the readiness of the industry to move to the next stage.
The program was intended to run from 2011 through 2021. The maximum number of years that each provider could participate was six years, with the first year being an “Adoption, Implementation, Upgrade” (A/I/U) year, resulting in the greatest incentive payment, with no required data attestation. For five subsequent years, each provider would track and attest to the appropriate measures for their current stage of participation. Providers could skip a year without penalty.
In October of 2015, CMS combined Stage 1 and Stage 2 standards into a single set of requirements, called “Modified Stage 2”. Modified Stage 2 requires providers to report on ten specific objectives, and in 2015 and 2016, various alternates and exclusions were included for those who were previously seeking to attest for Stage 1.
In August 2017, CMS published a Final Rule which stated that for 2017 and 2018, providers can choose to report on Modified Stage 2 objectives using a 2014-certified EHR, or report on Stage 3 objectives using a 2015-certified EHR (or a combination of 2014/15 certified EHR). In addition, providers can choose to report for a full year, or limit their reporting to any continuous 90-day period during the calendar year.
PCC Pediatric Practices: For practices still completing 2018 attestations, PCC clients should plan to attest to Meaningful Use “Stage 2 Modified” objectives. PCC is a 2014-certified EHR that meets or exceeds requirements for the Modified Stage 2 rules. When you attest, you will need PCC’s certification information, which is available at the bottom of pcc.com’s pricing page.
Current Status (2019)
With the introduction of the Promoting Interoperability program, requirements for incentive payments dropped to the state level. Providers are required to report on Stage 3 objectives using a 2015-certified EHR.
Future of Promoting Interoperability
The incentive program is expected to end in 2021.
We will keep you updated as we learn more!
Who is Eligible to Participate?
To qualify for Meaningful Use incentive funds, your pediatric practice must meet the following requirements:
- You must be an “Eligible Professional” (EP). EPs are physicians (MD, DO) and nurse practitioners. (PAs are not eligible.)
- You must be using a certified EHR (such as PCC EHR), in at least 50% of your patient encounters.
- At least 20% of the services offered by one or more pediatricians at your practice must be furnished to Medicaid patients in an outpatient setting. Nurse practitioners can also be part of your submission if 30% of their services are Medicaid.
Medicaid patient volume is calculated by dividing the provider’s encounters with Medicaid-enrolled patients over the provider’s total number of service encounters. PCC can help you find those numbers. Note that Children’s Health Insurance Program (CHIP) patients do not count toward the Medicaid patient volume criteria.
Your whole office can make workflow and policy changes to help meet Meaningful Use and report on CQMs, and your entire patient population can benefit from those changes. The reporting and evaluation for the EHR Medicaid Incentive program, however, and the resulting incentive, is always done based on eligible professionals who see a certain percentage of Medicaid patients.
When Can I Attest?
2017 is the last year to begin participation in the Meaningful Use program.
For all participants (new or returning), the 2017 EHR reporting period is any continuous 90-day period between January 1 and December 31, 2017. For the 2017 EHR reporting period, the attestation deadline is February 28, 2018.
Once you are part of the program, you may continue your participation for up to six years, through the program’s conclusion in 2021. You may stop participating at any time without penalty.
What Must I Do to Qualify for Funds from the Medicaid EHR Incentive Program?
To receive funds from the program, an eligible pediatrician must adopt, implement, upgrade, or meaningfully use their certified EHR technology.
Just by adopting PCC EHR or upgrading to the 2014-certified version of PCC EHR in your practice (prior to 2017), you met the qualification for your first year of participation in the Medicaid EHR Incentive program.
For instructions on meeting Modified Stage 2 requirements with PCC EHR, read Meet Meaningful Use with PCC.
For help with reporting on the 9 required Clinical Quality Measures (no minimum thresholds required), read How to Chart for Each Clinical Quality Measure in PCC.
How Much Money Can My Practice Receive From the Medicaid EHR Incentive Program?
In the first year of a pediatrician’s or nurse practitioner’s participation in the program, they can receive $21,250 if they have a 30-percent medicaid visit volume. Pediatricians that achieve 20% can receive 2/3rds of that amount, or $14,167.
In subsequent years, each eligible professional can receive $8500 for up to five years, depending on program participation.
So that is a per-provider incentive of up to $63,750 over 6 years.
Will I Get Audited?
Meaningful Use audits are happening more frequently as the program has progressed.
You may be asked to provide detailed proof that your attested Medicaid participant percentage is accurate. You may also need to give explanations of your Meaningful Use report calculations. If audited, you will be required to show documentation of your practice’s Security Risk Analysis, and a letter of verification of software use.
PCC Support can help you with all of these requirements.
Make sure that you save copies of reports and documentation, to make it easier to verify your data, should you be audited.
What Else Do I Need to Know?
Visit CMS.gov’s EHR Incentive Programs website to learn more.
The pages on that site can help provide an overview of the process, providing training videos and checklists for your attestation.
The Medicaid EHR Incentive Program is administered by your state’s Medicaid agency. There may be regional differences, state-by-state, and you should work closely with your state’s agency during your application process.
Finally, PCC Learn’s Meaningful Use, CQMs, ARRA’s EHR Medicaid Incentives, and PCMH section can help you figure out how to use PCC software to meet requirements of the EHR Medicaid Incentive program.