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NC Department of Health and Human Services
NC Division of
Medical Assistance
 
 

NC Medicaid Electronic Health Record Incentive Program

Frequently Asked Questions

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*Some of the FAQs found below have been adapted from the CMS FAQ Page.

Eligibility

 

Am I eligible for the NC Medicaid EHR Incentive Program?

Eligibility requirements are different for eligible professionals (EPs) and eligible hospitals (EHs). Detailed eligibility information is available on the CMS website.

There are some Nurse Practitioners (NPs) who are diploma credentialed and educated rather than having a Master’s Degree in nursing as a NP. Would these NPs have any difficulty getting enrolled in Medicaid?

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:

  1. Health assessment and diagnostic reasoning including:
    1. Historical data;
    2. Physical examination data; and,
    3. Organization of data base.
  2. Pharmacology;
  3. Pathophysiology;
  4. Clinical management of common health problems and diseases such as the following shall be evident in the nurse practitioner’s academic program:
  5. Respiratory system;
  6. Cardiovascular system
  7. Gastrointestinal system;
  8. Genitourinary system;
  9. Integumentary system;
  10. Hematologic and immune systems;
  11. Endocrine system;
  12. Musculoskeletal system;
  13. Infectious diseases;
  14. Nervous system;
  15. Behavioral, mental health and substance abuse problems;
  16. Clinical preventative services including health promotion and prevention of disease;
  17. Client education related to Subparagraph (b) (4)–(5) of this Rule; and,
  18. Role development including legal, ethical, economical, health policy and interdisciplinary collaboration issues.
    1. Nurse practitioner applicants exempt from components of the core curriculum requirements listed in Paragraph (b) of this Rule are:
      1. Any NP approved to practice in North Carolina prior to January 18, 1981, is permanently exempt from the core curriculum requirement; and,
      2. An NP certified by a national credentialing body prior to January 1, 1998, who also provides evidence of satisfying Subparagraph (b)(1)–(3) of this Rule shall be exempt from core curriculum requirements in Subparagraph (b)(4)–(7) of this Rule. 
    Evidence of satisfying Subparagraph (b)(1)–(3) of this Rule shall include:
    1. A narrative of course content; and
    2. Contact hours. 

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.

If an FQHC or RHC is led by a physician assistant (PA), are all PAs at that Federally Qualified Health Centers (FQHC) or Rural Health Centers (RHC) eligible for the Program?

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.

Are podiatrists, optometrists, and chiropractors eligible for the Medicaid EHR Incentive Program?

No. EPs under the NC Medicaid EHR Incentive Program include:

  • Physicians (primarily doctors of medicine and doctors of osteopathy);
  • Nurse practitioners;
  • Certified nurse midwives;
  • Dentists; and,
  • PAs who furnish services in an FQHC or RHC that is led by a PA.
Under the Medicaid EHR Incentive Program, are there a minimum number of hours per week that an EP must practice in order to qualify for an incentive payment? Could a part-time EP qualify for an incentive payment if the EP meets all other eligibility criteria?

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.

Are physicians who are employed directly by a tribally-operated facility and who meet all other eligibility requirements eligible for Medicaid EHR incentive payments?

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.

Will long-term care providers such as nursing homes be eligible for Medicaid EHR incentive payments?

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:

  • Physicians (primarily doctors of medicine and doctors of osteopathy);
  • Nurse practitioners;
  • Certified nurse midwives;
  • Dentists; and,
  • PAs who furnish services in a Federally Qualified Health Center or Rural Health Center that is led by a PA.
Are ambulatory surgical centers eligible for a Medicaid EHR incentive payment?

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:

  • Physicians (primarily doctors of medicine and doctors of osteopathy);
  • Nurse practitioners;
  • Certified nurse midwives;
  • Dentists;
  • PAs who furnish services in a Federally Qualified Health Center or Rural Health Center that is led by a PA;
  • Acute care hospitals (which include critical access hospitals and cancer hospitals); and,
  • Children's hospitals.
Are EPs who practice in State Mental Health and Long Term Care Facilities eligible for Medicaid EHR incentive payments if they meet the eligibility?

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.

Are mental health practitioners eligible to participate in the Medicaid EHR Incentive Program?

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 (primarily doctors of medicine and doctors of osteopathy);
  • Nurse practitioners;
  • Certified nurse midwives;
  • Dentists;
  • PAs who furnish services in a Federally Qualified Health Center or Rural Health Center that is led by a PA;
  • Acute care hospitals (which include critical access hospitals and cancer hospitals); and,
  • Children's hospitals.
Will the resident physicians that are employed at university hospitals be eligible to participate in the Medicaid EHR Incentive Program?

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.
What are the requirements for dentists participating in the Medicaid EHR Incentive Program?

Dentists must meet the same eligibility requirements as other eligible professionals (EP) in order to qualify for payments under the Medicaid EHR Incentive Program.  This also means that for Stage 1 they must demonstrate all 15 of the core meaningful use objectives and five from the menu of their choosing.  The core set for Stage 1 includes reporting of six clinical quality measures (three core and three from the menu of their choosing.)  Several meaningful use objectives have exclusion criteria that are unique to each objective. EPs will have to evaluate whether they individually meet the exclusion criteria for each applicable objective as there is no blanket exclusion by type of EP.

For additional guidance on how on how dentists can reach MU, see the HRSA website.

Are pediatricians eligible to receive incentive payments?

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:

      • Enrolled with NC Medicaid as a pediatrics specialty; or,
      • Board certified by a national certification board in a Pediatrics, Adolescent or Child medical specialty area.

Please note, pediatricians may qualify for a reduced incentive payment with a reduced patient volume threshold of 20%.

Per the given definition, NPs are not eligible to qualify with a Medicaid PV threshold of 20%. All NPs need to meet the 30% Medicaid PV threshold to be eligible to receive an EHR incentive payment.

How does NC define 'hospital-based' for eligible professionals (EP)

A hospital-based eligible professional (EP) is defined as an EP who furnishes 90 percent or more of their covered professional services in either the inpatient (Place of Service 21) or emergency department (Place of Service 23) of a hospital. Covered professional services are physician fee schedule (PFS) services paid under Section 1848 of the Social Security Act. To determine whether an EP is hospital-based, EPs may use encounter data from either the fiscal year prior to program year or calendar year prior to program year.

Am I able to attest to adopt, implement, upgrade (AIU) even if I purchased my EHR several years ago?
Yes. So long as the provider is in their first year of participation and has not yet received an AIU payment, they are permitted to attest to AIU anytime after purchasing/implementing/upgrading their EHR.
I'm an NP who is classified on NCTracks as being a pediatrician. May I qualify at the reduced Medicaid PV threshold of 20%?
No. Medicaid recognizes an Eligible Professional as being a pediatrician only if they are a Doctor of Medicine (MD) or a Doctor of Osteopathic Medicine (DO) and meet one of the following requirements below:
      • Enrolled with NC Medicaid as a pediatrics specialty; or,
      • Board certified by a national certification board in a Pediatrics, Adolescent or Child medical specialty area.

 

NOTE: For more complete information about eligibility requirements, please refer to the Eligibility section of the CMS website.

 

Registration

 

Do I need to have an EHR system in order to register for the NC Medicaid EHR Incentive Program?

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. So while you do not need to have a certified EHR in order to register for the NC Medicaid EHR Incentive Program, you will not be able to successfully attest or receive an incentive payment until you have a certified EHR technology. ONC maintains the most up-to-date list of certified products on their website.

Do providers register only once for the Medicaid EHR Incentive Program, or must they register every year?

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.

For large practices, will there be a method to register all of the EPs at one time for the Medicaid EHR Incentive Program? Can EPs allow another person to register or attest for them?

Please note, the individual provider is liable for the information provided on the attestation.

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.

I need an NCID (North Carolina Identity Management identifier) in order to register for the program. For which type of account should I register?

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:

  • Business users request access to the State of North Carolina on the behalf of a business.
  • Individuals request access to conduct online transactions with the state of North Carolina. These users may or may not be citizens of the state.
  • State government employees are employed or contracted to work for an agency within the state of North Carolina government.
  • Local government employees are employed or contracted to work for a North Carolina county or municipality.

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.

I just recently moved to North Carolina, but received a Medicaid incentive payment from the state where I practiced last year. How do I attest this year with 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.

I have a new provider in our practice this year and they don't know if they have received an incentive payment. Where can I go to see if they have participated in, and received money for, the Medicare or Medicaid EHR Incentive Program?
This information can be found on CMS' Registration & Attestation System under the attesting provider's registration information.

 

General Program Information

 

What is the path to payment?

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."

Who do I contact for more information?

Effective June 1, 2013, the N.C. Medicaid EHR Incentive Program Help Desk will be moving.  Providers should use the phone number, email, and mailing addresses listed below for all correspondence with the N.C. Medicaid EHR Incentive Program, including program and attestation inquiries, sending in signed attestations and supporting documentation.

*Email:                     NCMedicaid.HIT@dhhs.nc.gov

Phone Number:      919-814-0180

Mailing Address:    NC Medicaid EHR Incentive Program, 2501 Mail Service Center, Raleigh NC 27699

*Email is the preferred method of submission.

Note: Effective June 1, 2013, the N.C. Medicaid EHR Incentive Program no longer accepts documentation via fax.

Where can I find help with the attestation process?

Attestation guides are posted on the NC-MIPS website to help providers with the attestation process.

Additional help is available:
The NC-MIPS Help Desk
Phone: 919-814-0180
Email: NCMedicaid.HIT@dhhs.nc.gov

What are the next steps after a provider completes an attestation?

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 the NC-MIPS Help Desk:

By Email: NCMedicaid.HIT@dhhs.nc.gov

By Phone: 919-814-0180

What if my EHR system costs more than the incentive payment? May I request additional funds?

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.

How does CMS define an FQHC and an RHC for the purposes of the NC Medicaid EHR Incentive Program?

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.

What do “program years,” “participation years,” and “payment years” mean?

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.

My Medicaid Provider Number (MPN) was deactivated and I was required to pay $100 to reinstate it to participate in the EHR Incentive Program. How can I avoid this in the future?

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.

Does NC verify the "installation" or "a signed contract" for AIU for participation in the Medicaid EHR Incentive Program?

As part of the requirements, providers need to prove they have adopted, implemented or upgraded to a certified EHR technology. One such way to prove this is through supporting documentation (e.g.: contract, software license agreement, etc.) 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.

Are Medicaid providers subject to penalties if they do not adopt EHR technology or fail to demonstrate meaningful use?

No, Medicaid does not have any penalty for not being a meaningful user, and no penalties will be made to Medicaid reimbursements.

However, Medicare eligible professionals (EPs) who do not demonstrate meaningful use for the Medicare EHR Incentive Program may be subject to payment adjustments beginning on January 1, 2015. Because payment adjustments are mandated to begin on the first day of the 2015 calendar year, CMS will determine the payment adjustments based on meaningful use data submitted prior to the 2015 calendar year.

These payment adjustments will be applied to the Medicare physician fee schedule amount for covered professional services furnished by the EP in 2015. EPs who do not demonstrate meaningful use is subsequent years will be subject to increased payment adjustments in 2016 and beyond.

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.

For a detailed powerpoint explaining these penalties, please click here.

I am on track to attest for a Stage 1 365-day Meaningful Use payment; am I able to use the one-time 90-day reporting period in 2014?
Yes. In an effort to allow providers time to adjust to system upgrades compliant with 2014 certification standards, attestations for program year 2014 allow a 90-day reporting period for ALL EPs regardless of participation year.It doesn’t matter if the provider is attesting for Stage 1 or Stage 2, all participants are being granted this one-time 90-day reporting period in 2014.
I am on track to attest for a Stage 2 365-day Meaningful Use payment; am I able to use the one-time 90-day reporting period in 2014?
Yes. In an effort to allow providers time to adjust to system upgrades compliant with 2014 certification standards, attestations for program year 2014 allow a 90-day reporting period for ALL EPs regardless of participation year.It doesn’t matter if the provider is attesting for Stage 1 or Stage 2, all participants are being granted this one-time 90-day reporting period in 2014.
If I am taking a Medicare hardship exemption, but participating in the NC Medicaid EHR Incentive Program, do I have to file any paperwork with NC Medicaid?

EPs who are applying for hardship exemptions will do so with CMS. Providers do not need to file any paperwork or documentation with NC Medicaid. To find CMS' hardship exemption application, please click here.

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.

For a detailed powerpoint explaining these penalties, please click here.

Please note, Medicaid does not have any provider penalties for not being deemed a meaningful user.

Am I able to skip a year of attestation and pick back up where I left off when I attest next year, without missing out on a payment or being penalized?

Participation years do not need to be consecutive. An EP may choose to skip a Program Year(s) and will have the opportunity to pick up where they left off when they return to attest. In other words, if an EP was going to attest to Stage 1 90-day MU in Program Year 2014, but skips Program Year 2014 and returns to attest in Program Year 2015, they'll attest to Stage 1 90-day MU in Program Year 2015.

There are no penalties for skipping years of participation. So long as the EP participates for six years before 2021, they have the opportunity to earn the full incentive payment.

 

Eligible Professionals

 

What documentation is needed to demonstrate eligibility for being a PA-led facility?

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.

In order to qualify as an encounter, an EP must “see a patient.” How does an EP determine whether a patient has been “seen by the EP” in cases where the service rendered does not result in an actual interaction between the patient and the EP? Do patients seen via telemedicine qualify as an encounter?

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. In other words, an encounter is a unique patient on a unique day with a unique provider.

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.

How will NC Medicaid determine whether an EP is hospital-based?

NC Medicaid will use data from the prior calendar year or the 12 months immediately preceding the date of attestationto determine whether an EP is hospital-based.

What is the latest date an EP can submit a Program Year 2013 attestation?

North Carolina has adopted an attestation tail period of 120 days to allow for attestation beyond the end of the payment year.  This means that EPs will have until April 30, 2014 to submit a Program Year 2013 attestation.

I am an office manager attesting on behalf of an EP. May I sign the attestation or does it need to be signed by the attesting EP?

All signed attestations must be signed by the attesting EP. Please note, we do not accept electronic signatures.

I attested with Medicare's EHR Incentive Program last year but switched to Medicaid's EHR Incentive Program. Do I attest for another first year incentive payment since this is my first year attesting with Medicaid?
No. If an EP attests with ANY EHR Incentive Program (Medicare or another state Medicaid EHR Incentive Program), that counts as a year participation in the EHR Incentive Program. So if the EP attested with Medicare during their first participation year, when attesting with Medicaid, the EP would be attesting for a year 2 payment (Stage 1 90-day MU).

 

For more information, please see the CMS EHR Incentive Programs website.

 

Payment

 

In order to receive payments under the NC Medicaid EHR Incentive Programs, does a provider have to be enrolled in the Provider Enrollment, Chain, and Ownership System (PECOS)?

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.

What safeguards are in place to ensure that Medicaid EHR incentive payments are used for their intended purpose?

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.

After successfully demonstrating MU for the Medicaid EHR Incentive Program, will incentive payments be paid as a lump sum or in multiple installments?

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.

Where can I find my incentive payment on my RA (Remittance and Status Advice)?

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.

Can EPs receive EHR incentive payments from both the Medicare and Medicaid programs?

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.

Do recipients of Medicaid EHR Incentive Payments need to file reports under Section 1512 of the American Recovery and Reinvestment Act (ARRA) of 2009?

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.

Are payments from the NC Medicaid EHR Incentive Program subject to federal income tax?

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:

  1. If you assign your payment to a third party (such as your group practice), CMS is still obligated to report a payment to the eligible professional him or herself. The eligible professional will then bear a reporting obligation with respect to the assignment to a third party. CMS would not have a reporting obligation with respect to the third-party assignee unless CMS exercised managerial oversight with respect to, or had a significant economic interest in, the assignment.
  2. Recipients must include incentive payments as part of their gross income unless they receive payments as a conduit or an agent of another and are thus unable to keep the payments. For example, Dr. Smith works at ABC Healthcare and they use a 3rd party billing agency. Dr. Smith’s Electronic Funds Transfer (EFT) may get sent to the 3rd party billing agency and redirected directly to Dr. Smith. Be that the case, the 3rd party billing agency would not need to include the EHR incentive payment as gross income, but Dr. Smith would need to include the EHR incentive payment as gross income.
  3. To see the CMS reporting requirements with regard to eligible providers, see section 6041 of the Internal Revenue Code.

For specific provider questions, please call the Internal Revenue Service (IRS) toll-free at 800-829-3903.

Do EP incentive payments go to the professionals or to the professional's practice?

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.

How do I track an NC Medicaid EHR incentive payment?

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.

I attested for an incentive payment, but I entered the wrong payee NPI and the wrong person and/or organization was paid. What can I do to reassign the payment or deal with tax liability?

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.

I attested for an incentive payment, but a payee other than the payee specified in the CMS’ Registration and Attestation System was paid. What can I do to reassign the misdirected payment?
If a payee other than the payee specified in the CMS’ Registration and Attestation System was paid, please contact NC Medicaid at 919-814-0180. Our program representatives will work with providers on a case by case basis to resolve the issue.
Will the sequestration impact Medicaid EHR Incentive Payments?

Per the federal sequestration, a 2% reduction will be applied to any Medicare EHR incentive payment for a reporting period that ends on or after April 1, 2013. This sequestration will not impact Medicaid payments for the EHR Incentive Program.

Will my incentive payment be a direct deposit or issued via a check?

The payment is made via electronic funds transfer (EFT) to the account associated with the payee NPI/payee EIN given during attestation. Also, note that 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. 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.

 

Patient Volume for Eligible Professionals

 

How is PV calculated?

EPs need 30% Medicaid PV (20% for Pediatricians - for a reduced payment) 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

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.

Examples of billable services include:

  • Encounters denied for payment by Medicaid or that would be denied if billed due to exceeding the allowable limitation for the service/procedure;
  • 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;
  • Encounters denied for payment due to not billing in a timely manner;
  • Encounters paid by another payer which exceed the potential Medicaid payment; and,
  • 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.

Billable services do not include:

  • 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,
  • Encounters denied for payment by Medicaid because the patient was not enrolled in Medicaid at the time the service was rendered.
When EPs work at more than one clinical site of practice, are they required to use data from all sites of practice to support their PV thresholds for the NC Medicaid EHR Incentive Program?

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.

What Medicaid PV threshold must pediatricians meet to be eligible for incentive payments?

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:

      • Enrolled with NC Medicaid as a pediatrics specialty; or,
      • Board certified by a national certification board in a Pediatrics, Adolescent or Child medical specialty area.

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.

Are Pediatric Nurse Practitioners eligible for the reduced 20% Medicaid PV ratio?

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.

Do FQHCs or RHCs have to meet the 30% minimum Medicaid PV threshold to receive a Medicaid EHR incentive payment?

*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.

When calculating PV, can EPs that practice primarily in a clinic, but also see patients in hospitals, count their inpatient and outpatient hospital visits as encounters?

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.

For the Medicaid EHR Incentive Program, how do we determine Medicaid PV for procedures that are billed globally, such as obstetrician (OB) visits or some surgeries?

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.

When we count encounters in a clinic or medical group (or medical home model) for purposes of the Medicaid EHR Incentive Program, are we able to include the encounters of ancillary providers such as pharmacists, educators, etc. when determining if the EPs are eligible, per PV requirements?

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.

If an EP in the Medicaid EHR Incentive Program wants to leverage a clinic or group practice’s PV as a proxy for the individual EP, how should a clinic or group practice account for EPs practicing part-time and/or applying for the incentive through a different location (e.g., where an EP is practicing both inside and outside the clinic/group practice, such as part-time in two clinics)?

EPs may use a clinic or group practice’s PV as a proxy for their own under four conditions:

  1. The clinic or group practice’s PV is appropriate as a PV 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 PV determination;
  3. The EP has a current affiliation with the groups' PV they are using to attest; and,
  4. So long as the practice and EPs decide to use one methodology for a 90-day reporting period (in other words, clinics could not have some of the EPs using their individual PV for patients seen at the clinic, while others use the clinic-level data during the same 90-day reporting period). The clinic or practice must use the entire practice’s PV and not limit it in any way. EPs may attest to PV 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.

For more information, please see Attachment E in the NC Medicaid EHR Incentive Program's Special Bulletin.

Are FHQC look-alike's eligible for the “practicing predominantly in an FQHC” requirement of the NC Medicaid EHR Incentive Program, allowing them to use needy individual encounters toward the PV requirement?

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.

Is it permissible to count services provided to "presumptive eligible" recipients in the PV calculation?

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.

What is the patient volume calculation for Program Year 2013 and beyond?

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.

How do I calculate my PV numerator?

In general, providers should follow the general guidelines below:

  1. Determine the total number of encounters during the PV reporting period
  2. From the total number of encounters, determine which patients are Medicaid-enrolled (The EP/EH must have a mechanism for determining who is Medicaid-enrolled…this will be VERY important if they are selected for audit)
  3. From the list of Medicaid-enrolled encounters, determine which encounters are considered ‘billable services.’

If you have more questions on how to calculate patient volume, please refer to the Understanding Patient Volume webinar on our website.

What are billable services?

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.

Do I need to use the same reporting period for Patient Volume and Meaningful Use?
No. These are two distinctly different reporting periods, so it is not required to use the same reporting period. Providers can select a PV reporting period from the previous calendar year or the 12 months immediately preceding the date of attestation. While the MU reporting period must be selected from the current calendar year.
Will my payment be delayed if my patient volume reporting period includes days after July 1, 2013?

Yes. Because of the move to NC Tracks, there will be a delay in verifying encounters from any PV reporting period that includes days after 7/1/13. If possible, you should select a PV reporting period prior to 7/1/13 to expedite payment. As always, it is best to select a PV reporting period as far from the attestation date as possible because of claims lag.

Note that this is a suggestion for expediting payment, but you may select any PV reporting period from the previous calendar year or the 12 months preceding attestation. See the patient volume podcast for additional information.

What is considered to be an auditable data source?

You must be able to support all of your attested PV numbers, including your Medicaid-enrolled zero-pay encounters, with an auditable data source, defined as an electronic or manual system that an external entity can use to replicate the data from the original data source to support their attested information.

If the providers in my practice attested using individual methodology to calculate patient volume last year but would like to attest using group methodology to calculate patient volume this year, is it okay for them to switch?
Yes. Providers are allowed to select their patient volume methodology each year of participation in the NC Medicaid EHR Incentive Program and it can alter year to year. That being said, if you can - go group!
How is ‘encounter’ defined for the NC Medicaid EHR Incentive Program?

For EPs, a Medicaid-paid encounter is defined as services rendered on any one day to an individual where Medicaid or a Medicaid demonstration project under Section 1115 of the Social Security Act paid for part or all of the service as stated in the Final Rule.

CMS further defines a patient encounter as any encounter where a medical treatment is provided and/or evaluation and management services are provided.

It is important to note that EPs must count actual encounters, defined as a unique patient on a unique day, from their own auditable data source, defined as an electronic or manual system that an external entity can use to replicate the data from the original data source to support their attested information.

Exclude anything from your numerator and denominator that’s not an encounter, such as management fees like system-generated management fees for Carolina Access -CCNC (ICN region code 80 on Medicaid claims).  These are paid Medicaid claims but there is no encounter.

Health Choice encounters may not be included in the numerator of the Medicaid patient volume calculation, except in the case of EPs who practice predominantly at a Federally Qualified Health Center (FQHC) or Rural Health Clinic (RHC). FQHCs and RHCs can include these as non-Medicaid needy in their numerator.

Zero-pay Medicaid encounters are encounters with Medicaid patients that were billable services but Medicaid did not pay.

A. 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.

B. 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).

C. 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.

D. 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.

How do I report incident to billing as part of my Medicaid Patient Volume calculation?

If your Medicaid-paid encounters were billed under another provider's NPI, you will need to answer the following question on the patient volume screen in MIPS:
11) If another EP was listed as attending on any of the encounters included in patient volume, enter that EP’s MPN and number of encounters attributable to that EP.

In other words, if another provider was listed as attending on any or all of the Medicaid-paid encounters included in your numerator, enter that other provider's NPI or MPN and number of Medicaid-paid encounters attributable to that other provider. Enter only Medicaid-paid encounters. If your Medicaid-paid encounters were billed under more than provider's NPI, list all.

If you do not provide this information in MIPS, we will not be able to validate your patient volume and your attestation will be denied.

For additional guidance, click here.

If any other provider used your NPI on Medicaid claims, you will need to answer the following question on the patient volume screen in MIPS:
10) If any other provider(s) used your MPN during the 90-day period, show the name(s) and number of encounters attributable to that provider.

In other words, if any other provider, such as a nurse practioner that you supervised or a physician that was new to your practice, used your personal NPI or MPN as attending/rendering on Medicaid claims, then you must enter the name of that other provider and the number of Medicaid-paid encounters that belong to that other provider. Enter only Medicaid-paid encounters. If more than one provider used your NPI, list all.

If you do not provider this information in MIPS, we will not be able to validate your patient volume and your attestation will be denied.

For additional guidance, please click here.

I am a nurse practitioner whose encounters were billed to Medicaid using a supervising physician's NPI on claims. How do I report my Medicaid-paid encounters?

If your Medicaid-paid encounters were billed under another provider's NPI, you will need to answer the following question on the patient volume screen in MIPS:
11) If another EP was listed as attending on any of the encounters included in patient volume, enter that EP’s MPN and number of encounters attributable to that EP.

In other words, if another provider was listed as attending on any or all of the Medicaid-paid encounters included in your numerator, enter that other provider's NPI or MPN and number of Medicaid-paid encounters attributable to that other provider. Enter only Medicaid-paid encounters. If your Medicaid-paid encounters were billed under more than provider's NPI, list all.

For additional guidance, please click here.

If you do not provide this information in MIPS, we will not be able to validate your patient volume and your attestation will be denied.

I am a physician who supervises a nurse practitioner. The NP uses my NPI on Medicaid claims. Do I need to report this when attesting?

Yes. If any other provider used your NPI on Medicaid claims, you will need to answer the following question on the patient volume screen in MIPS:
10) If any other provider(s) used your MPN during the 90-day period, show the name(s) and number of encounters attributable to that provider.

In other words, if any other provider, such as a nurse practioner that you supervised or a physician that was new to your practice, used your personal NPI or MPN as attending/rendering on Medicaid claims, then you must enter the name of that other provider and the number of Medicaid-paid encounters that belong to that other provider. Enter only Medicaid-paid encounters. If more than one provider used your NPI, list all.

If you do not provide this information in MIPS, we will not be able to validate your patient volume and your attestation will be denied.

For additional guidance, please click here.

Should I include encounters paid by Health Choice in my patient volume numerator?
Health Choice encounters may not be included in the numerator of the Medicaid patient volume calculation, except in the case of EPs who practice predominantly at a Federally Qualified Health Center (FQHC) or Rural Health Clinic (RHC). FQHCs and RHCs can include these as non-Medicaid needy in their numerator.
We have a new billing NPI. For patient volume, do we report our new NPI or old NPI?

On the patient volume page in MIPS, for practice billing NPI or group billing NPI, enter the NPI that you used as billing NPI on your Medicaid claims during your reported 90-day patient volume reporting period.

 

Meaningful Use

 

What is Meaningful Use (MU)?

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:

  1. Use of certified EHR in a meaningful manner (i.e., e-prescribing);
  2. Use of certified EHR for electronic exchange of health information to improve quality of health care; and,
  3. Use of certified EHRs to submit Clinical Quality Measures (CQM).

The ultimate goal is to bring about health care that is:

  • Patient-centered;
  • Evidence-based;
  • Prevention-oriented;
  • Efficient; and,
  • Equitable.
When EPs work at more than one clinical site of practice, are they required to use data from all sites of practice to support their demonstration of PV for the NC Medicaid EHR Incentive Program?

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.

If certified EHR technology possessed by an EP includes the ability to calculate clinical quality measures (CQMs) from the additional set that are not indicated by the EHR developer or on the Certified Health Information Technology Product List (CHPL) as tested and certified by an ONC - Authorized Testing and Certification Body (ONC-ATCB), can the EP submit the results of those CQMs to NC as part of their MU attestation?

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.

Once I receive my first payment, do I need to attest every consecutive year?

Medicaid EPs may receive payments on a non-consecutive, annual basis. 

Can an EP meet meaningful use without having seen any patients during their meaningful use reporting period?

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.

Do I need to use the same reporting period for Patient Volume (PV) and Meaningful Use (MU)?
No, these are two distinctly different reporting periods, so it is not required to use the same reporting period. Providers can select a PV reporting period from the previous calendar year or the 12 months immediately preceding the date of attestation. While the MU reporting period must be selected from the current calendar year.
The computerized provider order entry (CPOE) core Meaningful Use (MU) measure indicates that medical orders (medication, laboratory and radiology orders) needs to be directly entered by any licensed healthcare professional. How does the NC Medicaid EHR Incentive Program define a ‘licensed healthcare professional”?

For the purposes of the NC Medicaid EHR Incentive Program, a licensed healthcare professional is one who has been recognized by an accredited authorizing entity as being capable to practice healthcare in North Carolina. It is the responsibility of the practice to regulate that only those employees who are authorized to enter orders into the medical record per state, local, and professional guidelines are doing so to meet the CPOE measure.

Please note, the order must be entered by someone who could exercise clinical judgment in the case that the entry generates any alerts about possible interactions or other clinical decision support aides. This necessitates that CPOE occurs when the order first becomes part of the patient's medical record and before any action can be taken on the order.

Is a patient portal required to meet Stage 1 MU?
For the sole purposes of meeting Stage 1 MU, a patient portal is not required. That being said, please note, there are new 2014 EHR certification standards required by ONC . To see if your EHR technology is compliant with 2014 certification standards, please click here.

 

Technology

 

Do providers have to contribute a minimum dollar amount toward their certified EHR technology for the NC Medicaid EHR Incentive Program?

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.

Where can I get answers to my privacy and security questions about EHRs?

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.

What is the purpose of certified EHR technology?

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.

Must providers have their EHR technology certified prior to beginning the EHR reporting period in order to demonstrate MU under the Medicaid EHR Incentive Programs?

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.

How do I know if my EHR system is certified? How can I get my EHR system certified?

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.

My EHR system is certified by the Certification Commission of Health IT (CCHIT). Does that mean it is certified for the Medicaid EHR Incentive Program?

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.

 

NC-MIPS

 

On the NC-MIPS Portal, what is the difference between the cancel and withdraw buttons?

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.

How do I withdraw and re-attest?

Please visit the NC-MIPS Portal at https://ncmips.nctracks.nc.gov/, withdraw the attestation for this provider and re-submit (previous data is saved) online. Please be sure to have the provider sign the attestation and submit the printed copy to one of the following:

Withdrawing and Re-attesting
Please visit the NC-MIPS Portal at https://ncmips.nctracks.nc.gov/, withdraw the attestation for this provider and re-submit (previous data is saved) online. Please be sure to have the provider sign the attestation and submit the printed copy to one of the following:

Mail:          NC Medicaid EHR Incentive Program, 2501 Mail Service Center, Raleigh, NC 27699-2501
Email:        NCMedicaid.HIT@dhhs.nc.gov

NC-MIPS is not displaying an address in the NC column on the Demographics page. What do I need to do?

If the North Carolina demographic information is not automatically populating within
NC-MIPS, please reference NCTracks to verify your information. If there are any discrepancies between the information on file with CMS or NCTracks, please contact them to update your information.

NCTracks (CSC) Call Center: 866-844-1113 or 800-688-6696
CMS EHR Information Center: 1-888-734-6433 or 1-888-734-6563

If the information matches between those two entities, you may continue with your attestation even if the information is not populating in the NC column.

My NCID username and password work on all other Medicaid sites, but I am getting an error when I try to login to NC-MIPS. What should I do?

Please ask yourself the following questions:

1. Has the eligible professional (EP) or eligible hospital (EH) already registered on CMS' Registration & Attestation (R&A) system?

If yes, 2. Has the EP or EH already completed the First Time Account Setup in NC-MIPS?

If yes, 3. Has the EP or EH changed their NCID username since completing the First Time Account Setup?

If so, please send an email with the provider(s) name(s), NPI(s), and NCID username(s) to NCMedicaid.HIT@dhhs.nc.gov.

For more NC-MIPS troubleshooting assistance, please refer to the NC-MIPS Quick Reference Guide.

Please refer to the EP AIU or MU Attestation Guides (right side of NC-MIPS) for more information on successfully registering and attesting for the NC Medicaid EHR Incentive Program.

I am receiving a warning message that I need to complete my registration with CMS. What do I need to do?

That message will populate if the CMS registration has not been fully submitted or if an EHR certification number was not entered during CMS registration.

To enter an EHR certification number on CMS' R&A system:

1.  Go to https://ehrincentives.cms.gov
2.  Click Continue
3.   Check the box, click continue
4.   Log in using the NPPES username & password
5.  Click on the Registration tab to continue
6.  Click on Modify in the Action column to continue
7.  Click on Topic 1 - "EHR Incentive Program"
8.  Click Yes at "Do you have a certified EHR?"
9.  Enter the EHR number
10.  Click Save & Continue
11.  Click Save & Continue
12.  Click Save & Continue
13.  Click on Proceed with Submission
14.  Review the information then click Submit Registration
15.  Click Agree

Please allow 24 hours for system updates. If you have any questions or need assistance, please contact the CMS EHR Information Center, Monday through Friday at 1-888-734-6433 or 1-888-734-6563 (TTY number) (Hours of Operation 7:30 a.m. – 6:30 p.m – CST – excluding Federal Holidays).

To ensure all CMS registration information is fully submitted:

1.  Go to https://ehrincentives.cms.gov
2.  Click Continue
3.   Check the box, click continue
4.   Log in using the NPPES username & password
5.  Click on the Registration tab to continue
6.  Click on Modify in the Action column to continue
7.  Click on Proceed with Submission
8.  Review the information then click Submit Registration
9.  Click Agree

I am trying to register on NC-MIPS but it is asking me for a Medicaid Provider Number (MPN). I enrolled with Medicaid after July 1, 2013 and was not issued an MPN. What should I put in that field?
If the EP enrolled with NC Medicaid after July 1, 2013, they may enter XXXXXXX in that field. Please refer to the EP AIU or MU Attestation Guides (right side of NC-MIPS) for more information.
If I make updates to my attestation, do I have to re-print & re-send the attestation documentation?

Yes. If the EP's attestation is in any way altered or updated, you will need to re-print and re-send the signed attestation. The EP's signature is authorizing that the information submitted was true and accurate. If any of the information changes, the EP's signature is no longer valid and will not be accepted.

If attesting to MU, and you had to re-submit your attestation, please either cross out the dates on the MU summary pages so it matches the date of the most recently submitted attestation or write a note on the new attestation/your letterhead stating the MU measures have not been altered.

 

Eligible Hospitals


If the state chooses to use the cost report in the Medicaid EHR incentive hospital payment calculation, what data elements should be used in the Medicare cost report, Form CMS 2552-96 and the Form CMS 2552-10?

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:

  • Total Discharges - Worksheet S-3 Part 1, Column 15, Line 12
  • Medicaid Days - Worksheet S-3, Part I, Column 5, Line 1 + Lines 6-10
  • Medicaid HMO Days - Worksheet S-3, Part I, Column 5, Line 2
  • Total Inpatient Days - Worksheet S-3 Part 1, Column 6, Line 1, 2 + Lines 6 -10
  • Total Hospital Charges - Worksheet C Part 1, Column 8, Line 101
  • Charity Care Charges - Worksheet S-10, Column 1, Line 30

The CMS 2552-10 data elements are as follows:

  • Total Discharges - Worksheet S-3 Part 1, Column 15, Line 14
  • Medicaid Days - Worksheet S-3, Part I, Column 7, Line 1 + Lines 8-12
  • Medicaid HMO Days - Worksheet S-3, Part I, Column 7, Line 2
  • Total Inpatient Days - Worksheet S-3 Part 1, Column 8, Line 1, 2 + Lines 8 - 12
  • Total Hospital Charges - Worksheet C Part 1, Column 8, Line 200
  • Charity Care Charges - Worksheet S-10, Column 3, Line 20

** 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.

A number of measures for MU objectives for EHs include patients admitted to the Emergency Department (ED). Which ED patients should be included in the denominators of these measures for the Medicaid EHR Incentive Program?

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:

  • The patient is admitted to the inpatient setting (place of service (POS) 21) through the ED. In this situation, the orders entered in the ED using certified EHR technology would count for purposes of determining the computerized provider order entry (CPOE) MU measure. Similarly, other actions taken within the ED would count for purposes of determining MU.
  • The patient initially presented to the ED and is treated in the ED’s observation unit or otherwise receives observation services. Details on observation services can be found in the Medicare Benefit Policy Manual, Chapter 6, Section 20.6. Patients who receive observation services under both POS 22 and POS 23 should be included in the denominator.
  • All ED Visits method. An alternate method for computing admissions to the ED is to include all ED visits (POS 23 only) in the denominator for all measures requiring inclusion of ED admissions. All actions taken in the inpatient or emergency departments (POS 21 and 23) of the hospital would count for purposes of determining meaningful use.
Prior to hospitals converting over to cost report 2552-10, both Charity Care and Bad Debt were combined and reported as Uncompensated Care on worksheet S-10 of the former hospital cost report 2552-96. As Charity Care is a required field in NC-MIPS, how should EHs calculate and report Charity Care in NC-MIPS for years that utilized old cost reports?

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.

What information is required for EHs to attest in NC-MIPS and where do they find it?

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.

When is the earliest an EH may attest for a year-two payment?

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.

Are nursery days and nursery discharges (for newborns) included as acute-inpatient services in the calculation of hospital incentives for the Medicaid EHR Incentive Program?

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.

Will nursery days (for newborns) be included as inpatient-bed-days in the calculation of hospital incentives for the Medicaid EHR Incentive Program?


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.

If an EH is dually-eligible and initially registers only for the Medicaid EHR Incentive Program, but later decides that it wants to also register for the Medicare EHR Incentive Program, can it go back and change its registration from Medicaid only to both Medicare and Medicaid?

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.

For calculation of a Medicaid hospital’s EHR incentive payment, is the estimated growth rate for hospitals most recent three years based on growth in total days or growth in discharges?

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.

How can an EH or CAH avoid a Medicare payment adjustment?

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.

For a detailed powerpoint explaining these penalties, please click here.

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 NCMedicaid.HIT@dhhs.nc.gov.

What is the latest date an EH can submit a 2013 attestation?

North Carolina has adopted anattestation tail period of 120 days to allow for attestation beyond the end of the payment year.  This means that EHs will have until January 28, 2014 to submit a 2013 attestation.

Can a state use two different 12-month periods to calculate the discharge-related amount and the Medicaid share?

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).

If I didn’t provide four consecutive periods of full 12-month Medicaid cost report data when I submitted my first year attestation, do I need to submit additional cost report data when I submit attestations for my second and third year payments?

Yes. The NC Medicaid EHR Incentive Program requires four consecutive periods of full 12-month Medicaid cost report data to accurately complete the final calculation of your incentive payment. Eligible hospitals who included less than four consecutive periods of full 12-month Medicaid cost report data with their first attestation, are required to submit additional cost report datawith future attestations until they have met the cost report data requirement. The NC Medicaid Incentive Payment System (NC-MIPS) will prompt EHs for additional cost report data as needed. Please note that DMA will recalculate the total incentive payment amount each time additional cost report data is submitted, which could result in payment adjustments.

If I did provide four consecutive periods of full 12-month Medicaid cost report data when I submitted my first year attestation, do I need to submit additional cost report data when I submit attestations for my second and third year payments?
No. Those hospitals who are attesting for a year 2 or 3 payment, and provided all cost report data in their first year, do not need to provide cost-report data or patient-level documentation with their attestation.

 

Audits

 

Who will be conducting audits for the NC Medicaid EHR Incentive Program?

The NC Medicaid EHR Incentive Program will be conducting AIU audits for eligible professionals (EP) and eligible hospitals (EH). The NC Medicaid EHR Incentive Program will also conduct MU audits for EPs. CMS will be conducting MU audits for EHs.

What can I do to prepare my organization in case of audit?

An audit may include a review of any of the documentation needed to support the information that was provided in the attestation.

The primary documentation that will be requested for all North Carolina audits are supporting documentation that the provider used when completing the attestation. This documentation should come from an auditable data source and provide a summary of the data that supports the information entered during attestation. Ideally, this would be a report from the certified EHR system, but other documentation may be used if a report is not available or the information entered differs from the report. 

This summary document will be the starting point of most reviews and should include, at minimum:
• The numerators and denominators for the measures
• The time period the report covers
• Evidence to support that it was generated for that eligible professional, eligible hospital, or critical access hospital.

EPs and EHs are encouraged to maintain all documentation for at least six years post-payment in case of an audit. The EP/EH will be held accountable for all information provided in their attestation, so they will need to prove everything to which they attest.

CMS has provided a detailed FAQ to prepare EPs/EHs in case of audit. To see the auditing FAQ, please click here.


If an EP fails an audit of their first year payment ($21,250) and the money is recouped by the state, can the EP attest again for a first year payment later in the program and still receive the first payment of $21,250?

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).

What is considered to be an auditable data source?

In the event of an audit, at a minimum, providers should have available electronic or paper documentation that supports providers’ completion of the Attestation Module responses, including the specific information that supports each measure.

In addition, providers should have documentation to support the submission of CQMs, including the
specific information that supports each measure. Providers should also maintain documentation to support
their incentive payment calculations, for example data to support amounts included on their cost report, which are used in the calculation. As indicated in the Stage 1 final rule, providers should keep documentation for at least 6 years following the date of attestation.

 

Contact Us

Providers should use the phone number, email, and mailing addresses listed below for all correspondence with the N.C. Medicaid EHR Incentive Program, including program and attestation inquiries, sending in signed attestations and supporting documentation.

*Email:                  NCMedicaid.HIT@dhhs.nc.gov

Phone Number:       919-814-0180

Mailing Address:    NC Medicaid EHR Incentive Program, 2501 Mail Service Center, Raleigh NC 27699

*Email is the preferred method of submission.

Note: Effective June 1, 2013, the N.C. Medicaid EHR Incentive Program no longer accepts documentation via fax.

 

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