Medicaid EHR Incentive Program for Eligible Professionals attesting to Adopt, Implement, Upgrade (AIU) or Modified Stage 2 Meaningful Use (MU) for Program Year 2015 March 2016

2 Disclaimer This presentation was current at the time it was presented, published or uploaded onto the web. This presentation was prepared as a service to the public and is not intended to grant rights or impose obligations. This presentation may contain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be a general summary. It is not intended to take the place of either the written law or regulations. We encourage attendees to review the specific statutes, regulations, and other interpretive materials for a full and accurate statement of their contents. Massachusetts eHealth Institute

Medicaid EHR Incentive Payment Program 3 Support MassHealth with the following program functions:  Program Planning and Administration  Enrollment and Eligibility Verification  Attestation and Pre-Payment Verification  Reconsideration and Appeals  Program Reporting to State and Federal Government agencies MeHI’s role in administering the Program

Important Timelines ©2013 Massachusetts eHealth Institute. All Rights Reserved. Confidential. 4 Program Year 2015 began on January 1, 2015 and ended on December 31, 2015  The attestation window for Adopt, Implement and Upgrade (AIU) is now through August 14, 2016  The attestation window for Meaningful Use (MU) is May 20, 2016 through August 14, 2016  Deadlines to submit other program documents: Special Enrollment and Data Collection Forms - May 31, 2016 Hospital Ambulatory Group Proxy Information - June 15, 2016 Resident Proposals - June 15, 2016  Program Year 2016 is the last year to initiate participation in the Medicaid EHR Incentive Payment Program  2021 is the last year to receive payments under the Medicaid EHR Incentive Payment Program

First Year Attestation Options   Eligible Professionals (EPs) attesting for the first time may attest to either Adopt, Implement, Upgrade (AIU) or Modified Stage 2 Meaningful Use (MU)  Attesting to AIU does not exempt the EP from Medicare reimbursement penalties for failure to demonstrate Meaningful Use 5 ©2013 Massachusetts eHealth Institute. All Rights Reserved. Confidential. If the EP attests to Adopt, Implement, Upgrade (AIU) If the EP attests to Meaningful Use (MU) EP submits Medicare claims Medicare reimbursement penalty applies No penalty EP does not submit Medicare claims No penalty

Eligibility Criteria 6 ©2013 Massachusetts eHealth Institute. All Rights Reserved. Confidential.

7 Eligibility Criteria  EPs must meet the following eligibility criteria for each program year in which they are requesting a payment General Eligibility Criteria Eligible Provider Type Certified EHR Technology (CEHRT) Non-hospital-based: less than 90% an EP’s encounters occur in an inpatient [POS 21] or emergency room [POS 23] setting Patient Volume Threshold EPs attesting using Federally Qualified Health Center (FQHC) or Rural Health Clinic (RHC) patient volume data must practice predominantly at an FQHC or RHC (50% or more of the EP’s encounters over a 6-month period in the previous calendar year occurred at an FQHC or RHC) Massachusetts eHealth Institute

General Eligibility Criteria  Eligible Professionals (EPs) must meet all of the following: Enrolled in Massachusetts Medicaid Management Information System (MMIS) for the purpose of participating in the EHR Incentive Program EPs who are already listed as active in MMIS do not need to re-enroll Licensed to practice in Massachusetts No sanctions EPs can only receive one EHR Incentive Program payment from one state or program (Medicare or Medicaid) during any given program year Note: EPs can no longer switch from the Medicare EHR Incentive Program to the Medicaid EHR Incentive Program 8 ©2013 Massachusetts eHealth Institute. All Rights Reserved. Confidential.

Eligible Provider Types Medicaid Eligible Professionals Physicians (MD or DO) Residents – if the organization has an approved resident proposal on file with the Massachusetts Medicaid EHR Incentive Payment Program Nurse Practitioners Certified Nurse-Midwives Dentists – including limited license dentists Physician Assistants who furnish services in a Federally Qualified Health Center (FQHC) or Rural Health Clinic (RHC) led by a Physician Assistant Clinical Nurse Specialists – to be determined

Certified EHR Technology (CEHRT) 10 ©2013 Massachusetts eHealth Institute. All Rights Reserved. Confidential. For Program Year 2015, EPs who meet any of the criteria below are required to submit documentation to demonstrate that they are using 2014 CEHRT:  The EP did not receive a Medicaid EHR Incentive Payment for Program Year 2014  The EP changed employers or practice locations  The EP used the CEHRT flexibility rule for Program Year 2014 and/or upgraded to 2014 CEHRT during Program Year 2015

Patient Volume Threshold 11 Massachusetts eHealth Institute

12 Patient Volume Threshold  EPs may attest using individual or group patient volume encounters  A minimum 30% Medicaid patient volume threshold is required –however, non-FQHC/RHC, board-certified pediatricians may attest with 20-29% Medicaid patient volume threshold and receive a reduced, 2/3 payment  Please reference the updated Medicaid 1115 Waiver Population Grid to determine which Managed Care Organizations participate with MassHealth  The patient volume threshold reporting period is any continuous 90- day period in the calendar year prior to the program year, or within the 12-month period leading up to attestation. Massachusetts eHealth Institute

13 Medicaid Encounter Definitions Medicaid Paid Encounter Definition  One service, per day, per patient, where Medicaid or a Medicaid 1115 Waiver population paid of all or part of the service or paid for all or part of the individual’s premiums, copayments, or cost-sharing Medicaid Enrollee Definition  One service, rendered any day to a Medicaid or Medicaid 1115 Waiver enrolled individual, regardless of payment liability. This includes zero-pay encounters that may have been paid by Medicare or by another third party, and denied claims, excluding denied claims due to the provider or individual being ineligible on the date of service Examples of encounters that can be included: Paid claims encounters Claims denied due to non-covered services Claims denied due to timely filing Services rendered to Medicaid members that were not billed Massachusetts eHealth Institute

14 FQHC/RHC - Needy Individual Encounter Definition EPs that practice predominately at an FQHC/RHC can elect to meet a minimum 30% Needy Individual patient volume “Needy Individual” is defined as a person receiving care from any of the following: Medicaid or Medicaid1115 Waiver Population, CHIP and those dually eligible for Medicare and Medicaid (includes MCO and FFS) Uncompensated Care No cost or reduced cost services on a sliding scale based on individuals’ ability to pay Massachusetts eHealth Institute

15 Calculating Medicaid Patient Volume Threshold Medicaid Patient Volume Threshold = numerator: Medicaid Patient Encounters (over a continuous 90-day period) denominator: Total Patient Encounters (during the same continuous 90-day period)  Encounters with Children’s Health Insurance Program (CHIP) patients cannot be included in your Medicaid patient volume. A CHIP reduction factor must be applied to the numerator. The CHIP factor varies depending on your patient volume threshold reporting period. Contact MeHI to determine the correct CHIP factor percentage to use. Massachusetts eHealth Institute

16 Group Proxy Definition  A group is defined as two or more EPs who are practicing at the same site.  The group proxy option may be more advantageous for organizations that seek to decrease the administrative process and maximize the number of EPs participating in the Medicaid EHR Incentive Program.  Encounters from all providers (even those not eligible to participate in the program) must be included in the patient volume threshold calculations. A Group Roster of all providers within the group is required; the organization must identify and highlight which EPs (per regulations) are eligible for the incentive.  All EPs within the group must use the same group proxy option within the same program year. In other words, the organization cannot elect to use the individual option for some providers and one of the group proxy options for the other providers. Massachusetts eHealth Institute

17 Approved Group Proxy Options Group OptionDefinition Medical Group Practice or Health CenterEPs within the same group in the same practice location can combine their encounters to meet the required patient volume threshold. Physician Foundations that have separate NPIs or Tax IDsA group of Eligible Professionals who are employed by a Hospital Physician Foundation, which is generally a not-for- profit, wholly owned subsidiary of a health system can combine all encounters to meet the required patient volume threshold. Hospital owned Outpatient ClinicsA group of Eligible Professionals who work within the same Outpatient Clinic (Ambulatory) can combine all encounters to meet the required patient volume threshold. Each Outpatient Clinic is defined as a separate group. Stand-Alone Outpatient FacilitiesA group of Eligible Professionals who work in different Outpatient (Ambulatory) Clinics within the same building that is owned and operated by a Health Care Organization can combine all encounters to meet the required patient volume threshold. Multiple (Ambulatory) Clinics Effective January 26, 2015: Eligible Professionals that work in multiple (Ambulatory) clinics, in multiple locations can combine all encounters to meet patient volume threshold if all providers were employed by and the clinics owned/operated by the same health care organization. Massachusetts eHealth Institute

18 Patient Volume Threshold Reminders Massachusetts eHealth Institute  Remember to apply the Children’s Health Insurance Program (CHIP) factor to your numerator ONLY (not your denominator).  Include your out-of-state Medicaid encounters in your calculations by entering them in the appropriate field.  Include all locations used to determine Medicaid Patient Volume Threshold on your MAPIR application. The attesting address(es) listed in MAPIR should reflect all locations where the provider rendered services to satisfy the eligibility requirements.

Entering Individual Patient Volume in MAPIR Apply CHIP Factor of xxx% to Medicaid Only Encounters

Entering Group Level Patient Volume in MAPIR Enter Group NPI Number(s)

Entering Individual Patient Volume in MAPIR – FQHC/RHC

Entering Group Level Patient Volume in MAPIR – FQHC/RHC Enter Group NPI Number(s)

Registration and Payment 23 ©2013 Massachusetts eHealth Institute. All Rights Reserved. Confidential.

CMS Identity & Access (I & A) and Registration & Attestation System (CMS R&A) Medicaid Management Information System/Provider Online Service Center (MMIS/POSC) Medical Assistance Provider Incentive Repository (MAPIR) Registration & Attestation Federal & State systems working together to support the Massachusetts Medicaid EHR Incentive Payment Program:

How Do I Register? Step 1: Confirm EP’s NPPES, MMIS & licensure information is current Step 2: Designee will create I&A Account if registering on behalf of an EP Step 3: EP will log into NPPES to confirm designee may attest on their behalf Step 6: EP or designee will complete MAPIR application and submit for review Step 5: If the NPI/TIN match what’s in MMIS – EP or designee will receive a welcome to MAPIR Step 4: EP or designee will complete CMS R&A application EP or designee will complete CMS R&A application Please Note: EPs completing their own application should complete step 1 and 4-6

Registration Reminders  Ensure that you have a CMS Identity and Access (I&A) account, username and password. If you are a designee attesting on behalf of an EP, the EP must grant permission for you to attest on their behalf.  Ensure that you have demographic information (including full name, NPI, address, payee NPI, and payee TIN) readily accessible. All information entered into the CMS Registration and Attestation (R&A) system must match the information currently in the Massachusetts Medicaid Management Information System (MMIS). Any discrepancies will result in delays.  Select “Group Reassignment” if the EP is planning to reassign payment to the organization. Only select “My Billing TIN” if the EP will be assigning payment to themselves.  Print a copy of your successful submission page for your records.  Remember to update your CMS registration if you move to a new location, change employers, change your demographic information, or upgrade your certified EHR technology (CEHRT). This is true for both designees and EPs. The majority of registration issues are related to a change of address, employer, demographic information, or CEHRT.

CMS Final Rule: Modifications to MU for

Meaningful Use (MU)  Meaningful Use is at the core of the EHR Incentive Payment Programs  CMS distinguishes between Eligible Hospitals (EHs) and Eligible Professionals (EPs) – slightly different objectives and measures  Previous rulemaking established three stages of Meaningful Use: STAGE 1 - Data Capture and Information Sharing STAGE 2 - Advanced Clinical Processes STAGE 3 – Improved Outcomes 28

CMS Final Rule – Changes to EHR Reporting Periods  For Program Year 2015, all providers attest using an EHR reporting period of any continuous 90-day period within the calendar year  For Program Year 2016: first-time MU participants will attest using any continuous 90-day period within the calendar year returning participants will attest using a full calendar year (January 1, 2016 through December 31, 2016)  For Program Year 2017: first-time MU participants and anyone choosing to demonstrate Stage 3 will attest using any continuous 90-day period within the calendar year returning Stage 2 participants will attest using the full calendar year (January 1, 2017 through December 31, 2017) EPs may use 2014 or 2015 Edition CEHRT (2015 Edition CEHRT is required if attesting to Stage 3 MU)  For Program Year 2018, all providers will attest to Stage 3 MU using the full calendar year (January 1, 2018 through December 31, 2018) and will be required to attest using 2015 Edition CEHRT 29

CMS Final Rule – List of Objectives  Meaningful Use Objectives – Modified Stage 2 1.Protect Patient Health Information – Security Risk Analysis 2.Clinical Decision Support (CDS) 3.Computerized Provider Order Entry (CPOE) 4.Electronic Prescribing (eRx) 5.Health Information Exchange (HIE) – previously known as “Summary of Care” 6.Patient Specific Education 7.Medication Reconciliation 8.Patient Electronic Access (Patient Portal) 9.Secure Electronic Messaging 10.Public Health and Clinical Data Registry Reporting a.Immunization Registry Reporting b.Syndromic Surveillance Reporting c.Specialized Registry Reporting d.Reportable Lab Results Reporting (Eligible Hospitals only) 30

CMS Final Rule – Alternate Exclusions for Stage 1 EPs EPs who were scheduled to demonstrate Stage 1 MU in 2015 may attest using the following alternate measures and/or exclusions:  Objective 2: Clinical Decision Support Alternate Measure: Implement one clinical decision support rule.  Objective 3: Computerized Provider Order Entry (CPOE) Alternate Measure 1: For Stage 1 providers in 2015, more than 30% of all unique patients with at least one medication in their medication list seen by the EP during the EHR reporting period have at least one medication order entered using CPOE; or more than 30% of medication orders created by the EP during the EHR reporting period are recorded using CPOE Alternate Exclusion for Measure 2: Providers may claim an exclusion for measure 2 (laboratory orders) Alternate Exclusion for Measure 3: Providers may claim an exclusion for measure 3 (radiology orders) 31

CMS Final Rule – Alternate Exclusions for Stage 1 EPs, con’d  Objective 4: Electronic Prescribing Alternate Measure: More than 40% of all permissible prescriptions written by the EP are transmitted electronically using CEHRT  Objective 5: Health Information Exchange Alternate Exclusion: Provider may claim an exclusion (Stage 1 does not have an equivalent measure)  Objective 6: Patient-Specific Education Alternate Exclusion: Provider may claim an exclusion if they did not intend to select the Stage 1 Patient-Specific Education menu objective  Objective 7: Medication Reconciliation Alternate Exclusion: Provider may claim an exclusion if they did not intend to select the Stage 1 Medication Reconciliation menu objective  Objective 8: Patient Electronic Access Alternate Exclusion: Providers may claim an exclusion for the second measure of this objective, requiring that at least one (1) patient seen by the EP during the EHR reporting period (or patient-authorized representative) views, downloads or transmits to a third party his or her health information (Stage 1 does not have an equivalent measure) 32

CMS Final Rule – Alternate Exclusions for Stage 1 EPs, con’d  Objective 9: Secure Messaging Alternate Exclusion: Provider may claim an exclusion (Stage 1 does not have an equivalent measure)  Objective 10: Public Health Reporting Alternate Exclusions: Provider must attest to at least 1 measure from the Public Health Reporting Objective Measures 1-3. May claim an Alternate Exclusion for Measure 1, Measure 2, or Measure 3. An Alternate Exclusion may only be claimed for up to two measures, then the provider must either attest to or meet the exclusion requirements for the remaining measure described in (e)(10)(i)(C). 33

Supporting Documentation Requirements

 To minimize processing delays and improve operational efficiency, EPs or their appointed Designees are required to upload supporting documentation to MAPIR at the time of attestation.  Please reference:  2015 Supporting Documentation Guide  Patient Volume Templates - Patient Volume Templates  Meaningful Use Aggregation Form  Medicaid 1115 Waiver Form  CHIP Percentage Grid  If an application is submitted without the required supporting documentation, the EP or Designee will receive an and the application will be set back to Incomplete, which will delay the processing of the EP’s application.  All Patient Volume Files must have an insurance key to accurately determine abbreviations, display numerator with CHIP percent applied and be submitted in a searchable format.  Additional supporting documentation may be requested during the application review process. Supporting Documentation Requirements 35 ©2013 Massachusetts eHealth Institute. All Rights Reserved. Confidential.

 Upload all supporting documentation to MAPIR unless instructed otherwise. For more information about the supporting documentation required for Program Year 2015, please see the 2015 Supporting Documentation Guide.  Keep all documentation related to your Medicaid EHR Incentive Payment Program application for a minimum of 6 years in the event of an audit by authorized State or Federal Agencies. This includes detailed patient volume reports and all documentation related to your Meaningful Use (MU) objectives and measures. Always retain the original report(s) used to complete your MAPIR application; reports produced at a later date may not be accurate and will not be sufficient for audit purposes. MeHI staff may also request copies of these reports during the pre-audit process. Supporting Documentation Reminders 36 ©2013 Massachusetts eHealth Institute. All Rights Reserved. Confidential.

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