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NC Division of Medical Assistance |
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Clinical Coverage Policies and Provider Manuals
Proposed Medicaid Clinical Coverage Policies
Certified Health IT Product List (CHPL) 
CMS EHR Incentive Programs Website
CMS Registration and Attestation Information Web Page
CMS State Medicaid Information - Launch Times and HIT Websites
NC DHHS Health Information Technology Website
US HHS Health Information Technology Website
*Some of the FAQs found below have been adapted from the CMS FAQ Page.
Eligibility requirements are different for eligible professionals (EPs) and eligible hospitals (EHs). Detailed eligibility information is available on the CMS website.
NPs who meet the following education and certification requirements may begin registering for Medicaid at any time. Once they acquire a Medicaid Provider Number (MPN), they may register for the Medicaid EHR Incentive Program. To attest as an individual, the NP must have claims history for the selected reporting period under his/her own MPN to calculate patient volume. To attest as part of a group using group methodology, the NP may utilize existing group encounter data to calculate patient volume. North Carolina’s education and certification requirements for NPs are as follows:
History Note: Authority G.S. 90-18(14); 90-171.42;
Recodified from 21 NCAC 36.0227(d) Eff. August 1, 2004;
Amended Eff. December 1, 2009; December 1, 2006; August 1, 2004.
Yes, all PAs who furnish services in an FQHC or RHC that is PA-led are eligible professionals (EPs) under the NC Medicaid EHR Incentive Program, so long as the PAs meet all other Program eligibility requirements (30% Medicaid/needy individual PV/not hospital-based, etc.).
Like other EPs at an FQHC or RHC, upon receipt of attestation, eligible PAs may be asked to provide additional documentation of any services provide either at no cost or at reduced cost based on a sliding scale determined by the individuals’ ability to pay.
No. EPs under the NC Medicaid EHR Incentive Program include:
There are no restrictions on employment type (e.g., contractual, permanent, or temporary -regardless of number of hours worked). So a part-time EP who meets all other eligibility requirements could qualify for payments under the Medicaid EHR Incentive Program.
If the physician meets the other program eligibility requirements (they can demonstrate 30% Medicaid patient volume, they’ve demonstrated AIU or meaningfully used certified EHR technology, they are not hospital-based, etc.) then the fact that they are employed by a tribally-operated facility is irrelevant.
The nursing home institution is not eligible for an incentive payment; however, individual EPs who work at the nursing home may qualify for an NC Medicaid EHR incentive payment and may choose to assign their payment to the nursing home facility.
f the long-term care providers meet all other program eligibility requirements, they may qualify to receive incentive payments. EPs under the NC Medicaid EHR Incentive Program include:
The ambulatory surgical center is not eligible for an incentive payment; however, individual EPs working at the ambulatory surgical center may qualify for an NC Medicaid EHR incentive payment and may choose to assign their payment to the ambulatory surgical center.
Under Medicaid, EPs are:
If a provider meets eligibility requirements, the setting is irrelevant. This is true except for physician assistants (PAs), as they are eligible only when they are practicing at a Federally Qualified Health Center (FQHC) that is led by a PA or a Rural Health Center (RHC) that is so led.
Mental health providers would only be eligible for incentive payments if they meet the eligibility criteria of a Medicaid EP.
Under Medicaid, EPs are:
Physicians who furnish substantially all (defined as 90% or more) of their covered professional services in either an inpatient or emergency department of a hospital are considered to be hospital-based and are therefore not eligible for incentive payments under the Medicaid EHR Incentive Program. If a resident is a licensed physician who is employed by the hospital but does not meet the hospital-based definition above, the resident may be eligible to participate in the Medicaid EHR Incentive Program.
Beginning in payment year 2013, a hospital-based EP that can demonstrate to CMS that they funded the acquisition, implementation and maintenance of certified EHR technology (CEHRT), including supporting hardware and interfaces needed for meaningful use without reimbursement from an EH or CAH, and uses such CEHRT in the inpatient or emergency department of a hospital (instead of the hospital’s CEHRT), may be determined by CMS to be a non-hospital based EP and may be eligible to participate in the Medicaid EHR Incentive Program.Dentists must meet the same eligibility requirements as other EPs in order to qualify for payments under the Medicaid EHR Incentive Program.
North Carolina Medicaid recognizes an Eligible Professional as being a pediatrician if they are a Doctor of Medicine (MD) or a Doctor of Osteopathic Medicine (DO) and meet one of the following requirements below:
NOTE: For more complete information about eligibility requirements, please refer to the Eligibility section of the CMS website.
You do not need to have a certified EHR in order to register for the NC Medicaid EHR Incentive Program with CMS. However, CMS and NC require that EPs and EHs have adopted, implemented, or upgraded (AIU) certified EHR technology before they can attest with the state to receive an EHR incentive payment. ONC maintains and updates the most current list of certified EHR technologies.
Providers are only required to register once for the NC Medicaid EHR Incentive Program. However, they must successfully demonstrate that they have adopted, implemented or upgraded (AIU) (first participation year for Medicaid) or meaningfully used (MU) certified EHR technology each year in order to receive an incentive payment for that year.
Additionally, providers seeking the Medicaid incentive must annually re-attest to other program requirements, such as meeting the required patient volume thresholds.
In April 2011, CMS implemented functionality that allows an EP to designate a third party to register on his or her behalf. To do so, users working on behalf of an EP must have an Identity and Access Management System (I&A) web user account (User ID/Password) and be associated to the EP's NPI.
The North Carolina Medicaid EHR Incentive Payment System (NC-MIPS) system will not allow one person to use one NCID to attest for multiple EPs.
NCID is the standard identity management and access service provided to state, local, business, and individual users, and is required when registering for the NC Medicaid EHR Incentive Program. NCID accommodates many types of user communities, including:
Administrators are state and local government employees who can administer user accounts within the same organization, division(s) and/or section(s) for which he or she has administrative rights (i.e. Delegated Administrators, Application Administrators, Service Desk).
Providers who are not state or local government should register as Business users. However, in coordinating efforts with Medicaid eligibility and enrollment, including the re-credentialing process, those who are employed or contracted to work for a state agency or locality must register as state or local government employees, respectively. Any fees associated with obtaining an NCID for the purposes of attesting for an incentive payment cannot be waived by NC Medicaid.
Providers need to navigate to the CMS R&A System, update their state to "NC" and ensure their contact information is updated. After doing this, the provider should receive an email from NC Medicaid with further instructions about attesting with the state.
Please visit the NC Medicaid EHR Incentive Program website for detailed information on an EP's path to payment, including links and additional resources to assist you. To see visual guidance of the path to payment, click here.
For more information on the EH attestation schedule and path to payment, please visit the NC Medicaid EHR Incentive Program website and click on the tab labelled "Path to Payment."
There are two ways to get additional information about the Medicaid EHR Incentive Program.
For help with the attestation process, to inquire about the status of your attestation, or for technical issues with the NC-MIPS attestation portal, contact:
For questions about the program or process, contact:
Attestation guides are posted on the NC-MIPS website to help providers with the attestation process.
Additional help is available from:
NC-MIPS Operations Center
Phone: (866) 844-1113
Fax: (866) 844-1582
Email: ncmips@csc.com
Attestations are validated by multiple units within Medicaid in the order in which they are received. Once the validation process is completed, EPs will be notified via email regarding when they will receive an incentive payment.
Providers may also logon to NC-MIPS at any time to see the status of their attestation.
For questions about the status of an attestation, contact:
NC-MIPS Operations Center
Phone: (866) 844-1113
Fax: (866) 844-1582
Email: ncmips@csc.com
No. The NC Medicaid Incentive Program is not a reimbursement program. Maximum payments have been set by CMS for EPs and the EH payment is calculated prior to their attesting with the NC Medicaid EHR Incentive Program. For additional information, please visit CMS' website.
The Social Security Act at section 1905(l)(2) defines an FQHC as an entity which:
"(i) is receiving a grant under section 330 of the Public Health Service Act, or (ii)(I) is receiving funding from such a grant under a contract with the recipient of such a grant and (II) meets the requirements to receive a grant under section 330 of the Public Health Service Act, (iii) based on the recommendation of the Health Resources and Services Administration within the Public Health Service, and is determined by the Secretary to meet the requirements for receiving such a grant including requirements of the Secretary that an entity may not be owned, controlled, or operated by another entity; or (iv) was treated by the Secretary, for purposes of Part B of title XVIII, as a comprehensive Federally-funded health center as of January 1, 1990, and includes an outpatient health program or facility operated by a tribe or tribal organization under the Indian Self-Determination Act or by an urban Indian organization receiving funds under Title V of the Indian Health Care Improvement Act for the provision of primary health services."
RHCs are defined as clinics that are certified under section 1861(aa)(2) of the Social Security Act to provide care in underserved areas, and therefore, to receive cost-based Medicaid reimbursements.
In considering these definitions, it should be noted that programs meeting the FQHC requirements commonly include the following (but must be certified and meet all requirements stated above): Community Health Centers, Migrant Health Centers, Healthcare for the Homeless Programs, Public Housing Primary Care Programs, FQHC Look-Alike's, and Tribal Health Centers.
The NC Medicaid EHR Incentive Program extends 11 years, from 2011-2022. The program began in 2011 (program year one) and will count its program years consecutively.
EPs may participate in any six of the 10 program years. These years are called participation or payment years, and they do not have to be consecutive.
In participation or payment year-one, a provider will typically attest to AIU of a certified EHR technology. In participation or payment years two and beyond, they will demonstrate MU of that technology.
The EHR Incentive Program requires active Medicaid enrollment along with an active MPN to participate. Letters are generated to providers after 12 months of inactivity requesting the Medicaid status of that provider. If a provider wishes to remain enrolled in Medicaid, they have two weeks to respond. If they do not wish to remain enrolled in Medicaid, no response is needed. If a provider does not respond within the two-week period and wishes to re-enroll with Medicaid, a $100 charge is required.
It is optional for providers to submit documentation at the time of attestation. Per CMS’ guidance, North Carolina suggests keeping documentation related to incentive payments for six years post-attestation in case of an audit.
The Final Rule states, a PA would be leading an FQHC or RHC under any of the following circumstances:
(1) The PA is the primary provider in a clinic (for example, when there is a part-time physician and full-time PA, we would consider the PA as the primary provider);
(2) The PA is a clinical or medical director at a clinical site of practice; or,
(3) The PA is an owner of an RHC.
For eligibility, PA-led facilities should submit documentation on group letterhead speaking to one of the three requirements mentioned above.
A Medicaid encounter is defined as services rendered to an individual on a unique day where the individual was enrolled in a Medicaid program (or a Medicaid demonstration project approved under Section 1115 of the Social Security Act) at the time the billable service was provided.
All cases where the EP has an actual physical encounter with a patient and renders a service to the patient should be included in the denominator as “seen by the EP.”
All cases where patients are seen via telemedicine qualify as encounters. All telemedicine encounters must be included in the denominator, and those encounters where Medicaid paid part, or all of the services, should be included in the numerator.
In cases where the EP and the patient do not have an actual physical or telemedicine encounter, but the EP renders a minimal consultative service for the patient (like reading an EKG), the EP may choose whether to include the patient in the denominator as “seen by an EP” provided the choice is consistent for the entire EHR reporting period and for all the relevant meaningful use (MU) measures.
EPs who never have a physical or telemedicine interaction with patients must adopt a policy that classifies at least some of the services they render for patients as “seen by the EP.” This methodology must be consistent across the entire EHR reporting period and across MU measures that involve patients “seen by the EP.” Otherwise, these EPs would not be able to satisfy MU, as they would have denominators of zero for some measures.
NC Medicaid defines telemedicine as:
The use of two-way real-time interactive audio and video between places of lesser and greater medical capability and/or expertise to provide and support health care when distance separates participants who are in different geographical locations. A recipient is referred by one provider to receive the services of another provider via telemedicine.
NC Medicaid will use data from the prior calendar year to determine whether an EP is hospital-based.
Due to delays in the launch of MIPS 2.0 in 2012, North Carolina has extended the attestation tail period from 60 to 120 days for payment year 2012 to allow for attestation beyond the end of the payment year. This means that EPs will have until April 30, 2013 to submit a 2012 attestation.
For more information, please see the CMS EHR Incentive Programs website.
No, Medicaid EPs do not have to be enrolled in PECOS to receive incentive payments.
The Medicare EHR Incentive Program requires providers to be enrolled in PECOS, so EHs who choose to participate in both EHR Incentive Programs will be required to be enrolled in PECOS.
Any provider who sees Medicare patients will be penalized in Medicare reimbursements starting in 2015 if s/he has not demonstrated s/he is a meaningful user (either through Medicare or Medicaid EHR programs). There are no penalties to Medicaid claim payments.
For more information on EP penalty adjustments, please click here.
For more information on EH penalty adjustments, please click here.
For more information on CAH penalty adjustments, please click here.
Like the Medicare EHR Incentive Program, neither the statute nor the CMS final rule dictates how a Medicaid provider must use their EHR incentive payment.
EPs participating in the Medicare EHR Incentive Program will receive a single lump sum payment for each year they successfully demonstrate MU of certified EHR technology.
An EP has the opportunity to receive up to $21,250 in year-one and $8,500 each subsequent year they participate in the Program.
EH payments are calculated prior to their attestation. They will receive 50% of the total incentive payment amount in year 1, they will receive 40% of the total incentive payment in year 2, and will receive the final 10% of the total incentive payment in year 3.
An incentive payment can be found as a separate item on the RA after paid and denied claims in the “Payouts” section, before the Financial Summary page.
Providers will receive an email stating the amount they should be paid with the EFT date, which should make the payment easily identifiable on the RA.
Not for the same year. If an EP meets the requirements of both programs, they must choose to receive an EHR incentive payment under either the Medicare program or the Medicaid program. After a payment has been made, the EP may only switch programs once before 2015.
No. The Medicaid EHR incentive payments made to providers are not subject to ARRA 1512 reporting because they are not made available from appropriations made under the Act.
CMS notes that nothing in the HITECH Act excludes such payments from taxation or as tax-free income, so it is likely that payments would be treated like any other income. That being said, providers should consult with a tax advisor or the IRS regarding how to properly report this income on their filings.
In general, there are three things providers need to know regarding taxes and the NC Medicaid EHR Incentive Program:
For specific provider questions, please call the Internal Revenue Service (IRS) toll-free at 800-829-3903.
NC Medicaid EHR Incentive Payments for EPs are tied to individual professionals, but may be voluntarily reassigned to an employer or entity promotion the adoption of certified EHR technology. It is against federal and program rules for an organization to require that affiliated providers assign incentive payments to an organization or practice.
Once a provider has been approved for an NC Medicaid EHR incentive payment, the NC-MIPS Help Desk will email a letter to the provider giving the name of the designated payee, the amount to be paid and the EFT date, which should make the payment easily identifiable on the R&A.
The incentive payment can also be found as a separate item on the RA after paid and denied claims in the "Payouts" section, before the Financial Summary page.
The "checkwrite date" given on the payment letter can be used to reconcile the payment against the 835 or RA.
An EP may check the status of their attestation at any time by logging onto NC-MIPS.
Once a provider has assigned a payee in CMS’ Registration and Attestation System, completed attestation, and been paid, NC Medicaid will not reassign the same payment to a different payee. If a provider has assigned the payment to an unintended payee, the provider will need to facilitate a transfer of the payment between the actual and intended payee. The provider may request a corrected 1099 for 2012 from NC Medicaid by sending a copy of their 2012 1099 along with a W-9 for the group to NC Medicaid to request the 2012 incentive payment earnings be moved to the new (intended) payee’s tax ID. The process for requesting a corrected 1099 will be published in the January 2013 Medicaid bulletin. This will remove the incentive payment earnings from the actual (initial) payee and add the incentive payment to the new (intended) payee. Please note that corrected 1099s are mailed by NC Medicaid on April 1.
EPs need 30% Medicaid PV (20% for Pediatricians) to be eligible for the incentive program.
To calculate the Medicaid PV percentage, use the following formula:
Medicaid PV Percentage:
Medicaid PV = All billable services rendered on any one day to a Medicaid-enrolled individual, regardless of payment liability (this includes zero-pay claims) ÷
Total PV = All encounters, regardless of the payment method in the same 90-day period
Examples of billable services include:
Billable services do not include:
Please note: there has been a change to the patient volume reporting period. For participation year 2013, EPs may choose their patient volume reporting period. EPs may choose as their reporting period any consecutive 90-day period within the prior calendar year or preceding 12-month period from the date of the attestation.
EPs may choose one (or more) clinical sites of practice in order to calculate their PV. This calculation does not need to be across all of an EP’s sites of practice. However, at least one of the locations where the EP is adopting or meaningfully using certified EHR technology should be included in the PV.
North Carolina Medicaid recognizes an Eligible Professional as being a pediatrician if they are a Doctor of Medicine (MD) or a Doctor of Osteopathic Medicine (DO) and meet one of the following requirements below:
A pediatrician that demonstrates at least 30% Medicaid PV, along with all other program requirements, is eligible to receive the full incentive payment amount.
A pediatrician that demonstrates at least 20% Medicaid PV, along with all other program requirements, may also participate for a reduced payment valued at two-thirds the full incentive amount.
No. Pediatricians are the only group of EPs that qualify for the reduced 20% PV threshold. Other EPs, including nurse practitioners, must meet the regular requirement of 30% Medicaid PV.
North Carolina defines a pediatrician as a Doctor of Medicine (MD) or a Doctor of Osteopathic Medicine (DO) that is enrolled with NC Medicaid as a pediatrics specialty or is board certified by a national certification board in a Pediatrics, Adolescent or Child medical specialty area.
*Note: All incentive payments are tied to individual professionals or hospitals. Therefore, as entities, FQHCs and RHCs are not eligible to attest for and receive payment under the program. However, EPs who work at an FQHC or RHC may be eligible to participate and can use needy individuals to meet the PV threshold.
EPs who work at an FQHC or RHC and meet the eligibility requirements may participate in the NC Medicaid EHR Incentive Program if: 1) They meet Medicaid PV thresholds individually, or if the FQHC/RHC meets PV requirements as a group; or 2) They practice predominantly in an FQHC or RHC and have 30% needy individual PV. In addition to Medicaid-enrolled encounters, needy individuals include NC Health Choice patients as well as patient encounters where services were provided either at no cost or at reduced cost based on a sliding scale determined by the individuals’ ability to pay.
EPs may be eligible as individuals or as a group. For more information regarding group and individual methodology when calculating PV, click here or visit our website.
Yes. EPs may (but are not required to) count their hospital-based encounters (inpatient and outpatient) when calculating their PV. This rule must be applied consistently to both the numerator and the denominator.
As a reminder, professionals who have more than 90% of their patient encounters in an inpatient or emergency department setting are considered “hospital-based” and are not eligible for the EHR Incentive Program.*
*Beginning in payment year 2013, a hospital-based EP that can demonstrate to CMS that they funded the acquisition, implementation and maintenance of certified EHR technology (CEHRT), including supporting hardware and interfaces needed for meaningful use without reimbursement from an eligible hospital or CAH, and uses such CEHRT in the inpatient or emergency department of a hospital (instead of the hospital’s CEHRT, may be determined by CMS to be a non-hospital based EP and may be eligible to participate in the Medicaid EHR Incentive Program.
Global billing situations such as OB/GYN visits should be counted on the date of service, not the date of billing. Each individual date of service is considered to be one encounter. In these situations, Medicaid will account for multiple visits per global billing during the validation process.
CMS regulations did not address whether these non-EP encounters could be considered in the estimate of PV for the clinic. However, they believe a state would have the discretion to include such non-EP encounters in its estimates. NC allows these encounters to be included in the PV calculation.
Again, if these non-EP encounters are included in the numerator, they must be included in the denominator as well. States also must ensure that their methodology adheres to the conditions in 42 CFR 495.306(h), and specifically t 495.306(h)(4), which says: “(4) The clinic or group practice uses the entire practice or clinic’s patient volume and does not limit patient volume in any way.”
For more information, see the final rule.
EPs may use a clinic or group practice’s PV as a proxy for their own under four conditions:
For more information, please see Attachment E in the NC Medicaid EHR Incentive Program's Special Bulletin.
EPs practicing at an FQHC look-alike are eligible for the “practicing predominantly” requirement of the NC Medicaid EHR Incentive Program so long as they meet all the requirements EPs of an FQHC are subject to as defined by CMS. Eligibility for “practicing predominantly in an FQHC” allows the EP to use needy individual encounters toward the patient volume requirement.
For more information, please visit CMS' FAQs.
Yes. EPs and EHs may include patient encounters with presumptive eligible recipients in the patient volume calculation. Since presumptive eligibility is generally short-term, make sure the patient still had presumptive eligibility status when the service was provided in order to count it toward your Medicaid patient volume.
As of Program Year 2013, patient volume should be calculated as follows:
Numerator: Billable service rendered on any one day to a Medicaid-enrolled individual, regardless of payment liability. This includes zero-pay claims.
Denominator: All encounters during the PV reporting period.
In general, providers should follow the general guidelines below:
If you have more questions on how to calculate patient volume, please refer to the Understanding Patient Volume webinar on our website, or give us a call at 919-814-0180.
Examples of billable services include:
1. Encounters denied for payment by Medicaid or that would be denied if billed due to exceeding the allowable limitation for the service/procedure;
2. Encounters denied for payment by Medicaid or that would be denied if billed because of lack of following correct procedures as set forth in the state’s Medicaid clinical coverage policy such as not obtaining prior approval prior to performing the procedure;
3. Encounters denied for payment due to not billing in a timely manner;
4. Encounters paid by another payer which exceed the potential Medicaid payment; and,
5. Encounters that are not covered by Medicaid such as some behavioral health services, HIV/AIDS treatment, or other services not billed to Medicaid for privacy reasons, oral health services, immunizations, but where the provider has a mechanism to verify Medicaid eligibility.
Further, the Final Rule defines billable as follows:
1. Concurrent care or transfer of care visits;
2. Consultant visits; or,
3. Prolonged physician service without direct, face-to-face patient contact (for example, tele-health).
A consultant visit occurs when a provider is asked to render an expert opinion/service for a specific condition or problem by a referring provider. The visit does not have to be individually billable in instances where multiple visits occur under one global fee.
Billable services do not include:
1. Encounters denied for payment by Medicaid or that would be denied if billed because of absence of medical necessity under the state’s Medicaid clinical coverage policy; and,
2. Encounters denied for payment by Medicaid because the patient was not enrolled in Medicaid at the time the service was rendered.
MU refers to the use of certified EHR technologies by health care providers in ways that measurably improve health care quality and efficiency.
The ARRA defines MU as:
The ultimate goal is to bring about health care that is:
Any EP demonstrating MU must have at least 50% of their of their patient encounters during the EHR reporting period at a practice/location or practices/locations equipped with certified EHR technology capable of meeting all of the MU objectives.
The EP can submit results for CQMs in the additional set (Stage 1 Final Rule's Table 6: Clinical Quality Measures for Submission by Medicare or Medicaid EPs for 2011 and 2012 Payment Years) calculated by certified EHR technology, even if those CQMs were not individually tested and certified by an ONC-ATCB. CMS expects to revisit CQM requirements in more detail for later stages of meaningful use as well as the corresponding certification requirements.
Medicaid EPs may receive payments on a non-consecutive, annual basis.
No. An EP must have had performed at least one professional service during their meaningful use reporting period and would need to have met all meaningful use requirements to qualify for a meaningful use payment.
No. If the state has made a payment to an EP, and the EP later fails an audit, they must give the payment back to the state, and will be unable to re-attest to receive the first year payment of $21,250.
In other words, if the first year payment is recouped, an EP will be unable to get another first year payment. Similarly, if an EP has their second year payment recouped, they are ineligible to receive another second year payment.
Therefore, an EP that participates successfully for all six program years may receive up to $63,670; however, if the EP fails an audit and their first payment of $21,250 is recouped by the state, the most the EP would qualify for during the life of the program is $42,420 ($63,670 – $21,250 = $42,420).
As the payments are not a reimbursement of costs, providers are not required to contribute a minimum amount toward the purchase or maintenance of their certified EHR technology in order to participate.
The Office for Civil Rights (OCR) is responsible for enforcing the Privacy and Security rules related to the HITECH program. More information is available at OCR's website.
Certification of EHR technology will provide assurance to purchasers and other users that an EHR system or product offers the necessary technological capability, functionality, and security to help them satisfy the MU objectives for the Medicaid EHR Incentive Program. Providers and patients must also be confident that the electronic health information technology (IT) products and systems they use are secure, can maintain data confidentially, and can work with other systems to share information. Confidence in health IT systems is an important part of advancing health IT system adoption and realizing the benefits of improved patient care.
For more information, please visit the Office of the National Coordinator's website.
No. A provider may begin the EHR reporting period for demonstrating MU before their EHR technology is certified. Certification need only be obtained prior to the end of the EHR reporting period. However, MU must be completed using the capabilities and standards outlined in the ONC Standards and Certification Regulation for certified EHR technology.
The Medicaid EHR Incentive Program requires the use of certified EHR technology, as established by a new set of standards and certification criteria. Existing EHR technology needs to be certified by an ONC-Authorized Testing and Certification Body (ONC-ATCB) to meet these new criteria in order to qualify for the incentive payments. The Certified Health IT Product List (CHPL) is available online and as new products become certified and available, they will be updated on the site.
No. The Medicaid EHR Incentive Program requires the use of certified EHR technology, as established by a new set of standards and certification criteria. Existing EHR technology needs to be certified by an ONC-Authorized Testing and Certification Body (ONC-ATCB) to meet these new criteria in order to qualify for the incentive payments.
In short, the cancel button is used while an attestation is still in progress and the withdraw button is used after an attestation has been submitted through the NC-MIPS Portal.
The cancel button will be used when an EP or EH realizes they are unable to meet AIU or meaningful use for that year and do not want to proceed with their attestation. Selecting the cancel button will stop any correspondence from the NC Medicaid EHR Incentive Program for that year. After canceling an attestation, providers are still allowed to come back at any point and continue their attestation.
The withdraw button will be used when an EP or EH has submitted their attestation, but wishes to withdraw it from the validation process. This action may also be taken if an error is found on a submitted attestation. The user may withdraw the attestation, correct any information and re-submit for validation at any time. The information entered in the original attestation will be saved within the system, making resubmission easy for the provider.
Based on the Medicare cost report guidance, Form CMS 2552-96 will be used until the implementation of the new Medicare cost report, Form CMS 2552-10. Although the state may choose to use the following data elements, it is the states' and hospitals' responsibility to ensure the integrity and regulatory compliance of the data.
The CMS 2552-96 data elements are as follows:
The CMS 2552-10 data elements are as follows:
** As permitted by Medicare cost reporting regulations, some hospitals have included both inpatient days paid by a North Carolina LME / PIHP (Prepaid Inpatient Health Plan) and Medicaid eligible days in the Medicaid (Title XIX) HMO Inpatient Days cost report field. Hospitals are reminded that 42 CFR §495.310 permits only inpatient bed days in the calculation of the Medicaid share of the EHR payment. EHs who submit attestations for EHR payments should identify only those inpatient days from their Medicaid cost report which were paid by a North Carolina LME / PIHP in the HMO data field. Providers including HMO days on their EH attestations are required to provide patient level detailed documentation in support of the number of inpatient bed days listed in the HMO days’ data field of the attestation.
On September 17, 2010, CMS issued an FAQ that explained that their intent to include in the denominator visits to the emergency department (ED) of sufficient duration and complexity that all of the MU objectives for which the ED is included would be relevant. Therefore they explained that EHs and CAHs should count in the denominator patients admitted to the inpatient part of the hospital through the ED, as well as patients who initially present to the ED and who are treated in the ED’s observation unit or who otherwise receive observation services.
CMS is revising their revised FAQ to allow EHs, as an alternative, for Stage 1 of MU, to use a method that is consistent with the plain language of the regulation. There are two methods for calculating ED admissions for the denominators for measures associated with Stage 1 of MU objectives. EHs and CAHs must select one of the methods below for calculating ED admissions to be applied consistently to all denominators for the measures. That is, EHs and CAHs must choose either the “Observation Services method” or the “All ED Visits method” to be used with all measures. Providers cannot calculate the denominator of some measures using the “Observation Services method,” while using the “All ED Visits method” for the denominator of other measures. Before attesting, eligible hospitals and CAHs will have to indicate which method they used in the calculation of denominators.
Observation Services method. The denominator should include the following visits to the ED:
When entering information on older cost reports that do not contain separate fields for Charity Care, EHs should use cost report 2552-10 instructions to calculate their Charity Care for reporting in NC-MIPS.
EHs may not enter their total Uncompensated Care, inclusive of Bad Debt, in the Charity Care field in NC-MIPS. Below are the definition and instructions for reporting Charity Care from form CMS-2552-10, Section 4012, Worksheet S-10.
Charity Care: Health services for which a hospital demonstrates that the patient is unable to pay. Charity care results from a hospital's policy to provide all or a portion of services free of charge to patients who meet certain financial criteria. For Medicare purposes, charity care is not reimbursable and unpaid amounts associated with charity care are not considered as an allowable Medicare bad debt.
Line 20: Enter the total initial payment obligation of patients who are given a full or partial discount based on the hospital’s charity care criteria (measured at full charges), for care delivered during this cost reporting period for the entire facility. For uninsured patients, including patients with coverage from an entity that does not have a contractual relationship with the provider (column 1), this is the patient’s total charges. For patients covered by a public program or private insurer with which the provider has a contractual relationship (column 2), these are the deductible and coinsurance payments required by the payer. Include charity care for all services except physician and other professional services. Do not include charges for either uninsured patients given discounts without meeting the hospital's charity care criteria or patients given courtesy discounts. Charges for non-covered services provided to patients eligible for Medicaid or other indigent care program (including charges for days exceeding a length of stay limit) can be included, if such inclusion is specified in the hospital's charity care policy and the patient meets the hospital's charity care criteria.
EHs will need to enter information about their previous year PV (both Medicaid and total inpatient acute care and ED visits) and information from the prior years’ 12-month cost reports. For more information, see the NC-MIPS website. This is not an exclusive PV question, but we are providing a detailed answer about PV and a generic reference to other required cost report data? There should be a reference to the very first FAQ above and/or a link to a page that will outline the detailed cost report information required to attest.
North Carolina is now accepting year-two attestations through the NC-MIPS Portal.
EH participation is defined by Federal Fiscal Year (FFY). Typically, EHs may attest to meaningful use (MU) with CMS after the first 90 days of a FFY. CMS is currently accepting MU attestations; however, due to a planned system modification, EHs that are registered for only the NC Medicaid EHR Incentive Program but would like to change their registrations to dually-eligible for both the Medicaid and Medicare programs will not be able to attest with CMS for 90 days of MU measurements until at least April 1, 2012.
The attestation schedule for EHs can be found here.
Check the NC Medicaid EHR Incentive Webpage for updates.
No, nursery days and discharges are not included in inpatient bed-day or discharge counts in calculating hospital incentives. We exclude nursery days and discharges because they are not considered acute inpatient services based on the level of care provided during a normal nursery stay.
No, nursery days will not be included as inpatient-bed-days in the calculation of hospital incentives for the Medicaid EHR Incentive Program. Nursery days are excluded because they are not considered inpatient-bed-days based on the level of care provided during a normal nursery stay.
Hospitals that register only for the Medicaid program will not be able to manually change their registration (i.e., change to “Both Medicare and Medicaid” or from one program to the other) after a payment is initiated and this may cause significant delays in receiving a Medicare EHR incentive payment.
The average annual growth rate should be for discharges (see 1903(t)(5)(B), referring to the annual rate of growth of the most recent three years for “discharge data.”) We agree that the sources are different. Hospitals would probably have to use MMIS or auditable hospital records to get accurate discharge data rate of growth.
North Carolina Medicaid requires EHs to use full 12-month cost reports as the auditable data source to get accurate discharge data to determine the average annual rate of growth.
EHs and CAHs that are eligible to participate in the Medicare EHR Incentive Program may be subject to Medicare payment adjustments. To provide guidance around this, CMS has provided payment adjustment schedules. Click here to view the EH adjustment schedule table (NOTE – there is a typo in the third column of the last row on Table 16. The submission date should read July 1, 2019 – not 2014). If an EH is already a participant with the NC Medicaid EHR Incentive Program, please pay special attention to the first row of this table as it will impact you.
Click here for the CAH payment adjustment schedule table.
For further information about the Medicare payment adjustment schedule and hardship exceptions, please click here for CMS’ payment adjustment and hardship exception tipsheet.
All questions about the Medicare EHR Incentive Program or Medicare payment adjustments should be directed to CMS. Questions about how the Medicare payment adjustments affect participation in the Medicaid EHR Incentive Program may be directed to 919-855-4200 or NCMedicaid.HIT@dhhs.nc.gov.
Due to delays in the launch of MIPS 2.0 in 2012, North Carolina has extended the attestation tail period from 60 to 120 days for payment year 2012 to allow for attestation beyond the end of the payment year. This means that EHs will have until January 28, 2013 to submit a 2012 attestation.
No, the regulation is clear that the discharge-related amount must be calculated using a 12-month period that ends in the Federal fiscal year before the hospital’s fiscal year that serves as the first payment year. For more information see the Final Rule: 42 CFR 495.310(g)(1)((i)(B).
For technical issues or to inquire about the status of your attestation, contact:
For questions about the program or process, contact
