FAQs Relating to Eligibility for Eligible Professionals (EPs)
1) Q: What individual provider types are eligible for the Medicaid EHR Incentive Program?
A: Eligible Professionals (EPs) under the Medicaid EHR Incentive Program include:
2) Q: How do I figure out my patient volume necessary for this process?
A: To qualify for an incentive payment under the Medicaid EHR Incentive Program, an EP must meet one of the following criteria:
- Physicians (MD and DO)
- Nurse Practitioners
- Certified Nurse-Midwifes
- Physician Assistants (PA) practicing in a PA-led FQHC or a PA-led Rural Health Clinic (RHC)
3) Q: What is a patient encounter?
A: For the purpose of calculating EP patient volume, a Medicaid encounter means a service rendered to an individual on any one day where:
- A minimum 30% Medicaid patient volume based on Medicaid and total patient encounters
- If you are a Board-certified pediatrician, have a minimum 20% Medicaid patient volume based on Medicaid and total patient encounters
- Practice predominantly in a Federally Qualified Health Center or Rural Health Center and have a minimum 30% patient volume based on Medicaid encounters and encounters attributable to needy individuals
4) Q: What is the difference between a patient count and a patient encounter?
A: If you simply count the individual patients you have treated over a 90-day period, you may undercount patients you treated more than once in that 90-day period. Instead, to ensure a more accurate representation, use the encounter definition in FAQ #3. Be consistent, as the same method is used for both Medicaid encounters (numerator) and total encounters (denominator).
5) Q: Can HMO encounters be included as part of eligibility determination?
6) Q: What are some of the common mistakes made by those entering Eligibility information in the CHAMPS EHR module?
A: When entering eligibility information, be mindful of the following:
- Medicaid paid for part or all of the service; or
- Medicaid paid all or part of the individual’s premiums, co-payments, or cost-sharing. If Medicaid does not pay anything, then it is not a patient encounter.
7) Q: What if I did not have an EHR in 2010; can I still participate in the Medicaid EHR Incentive?
A: To be eligible for the Medicaid EHR Incentive Program in the first year, you must have purchased, acquired, or have access to a certified EHR system at the time of registration. So if you wish to register in 2011, you can do so even if you did not have a certified system during the 90-day period you are using for your 2010 Medicaid patient volume count.
8) Q: Is it better, as an eligible professional, to register using the “group proxy” option (using the encounter information from the entire practice) or to register using individual encounter information?
A: If your group as a whole can meet the 30% Medicaid patient volume number, we encourage you to use the “group proxy.” However, if you use this proxy method, all EPs in the group must use identical encounter information and EHR certification numbers.
9) Q: Our physicians have registered individually, even though they all belong to the same group, because they thought the incentive would be less if they registered as a group. Is this true?
A: No. The incentive would not be reduced because the physicians elected to use the “group proxy” option. The EHR incentive is an individual incentive, with each professional registering individually. The only part the “group” can play is in providing group encounter information as a proxy for the individual's own encounter numbers. This makes it easier for the individual EP to register but does not make it a “group” incentive.
10) Q: We will be joined by new physicians in our practice. Will they qualify for the incentive this year?
A: No, the new physicians will have to wait for next year’s registration, since they are not part of the group’s 90-day-reporting-period encounter numbers from the previous calendar year. However, they could use their own numbers from their previous practice(s) and register individually.
11) Q: What does it mean to register under “Adopt, Implement, or Upgrade” (AIU)?
A: Medicaid providers do not have to meet meaningful use criteria in their first year of participation. Instead, all first year EPs are required to attest to adopting, implementing, or upgrading an EHR. However, meaningful use criteria must be met in subsequent years.
- EPs should enter patient “encounters,” not patient counts (see FAQ #3).
- Be consistent when using the group proxy method. When registering, all individuals in the group should use identical group NPIs, patient volume numbers, and EHR certification numbers.
- The letters within the EHR certification number must be entered in all CAPS.
- If you are an EP registering individually, you must include all of your encounter information from every location in which you practice.
12) Q: Is qualifying patient volume always a consecutive 90-day period in the previous calendar year?
A: Yes, it is.
- Adoption – acquired certified EHR technology (e.g., evidence of purchasing or securing access to certified EHR technology)
- Implementation – began using EHR (e.g., staff training, data entry of patient demographic information on EHR)
- Upgrading – expanded EHR (e.g., upgraded to certified EHR technology or added new functionality to meet MU)
FAQs Relating to Eligibility for Hospitals
1) Q: Are hospitals eligible for both the Medicare and the Medicaid Incentives?
A: Yes, they can receive both incentives if they qualify for both.
2) Q: If the hospital is part of a group (e.g., a children’s hospital like DeVos Children’s Hospital that is part of a group such as Spectrum Health System), then do they register individually or as a group?
A: It should register individually.
FAQs Relating to Federal Level Registration
1) Q: How do I register for the Medicaid EHR Incentive Program?
A: Registration is a two-step process, beginning with registration at the federal level. Go to: https://ehrincentives.cms.gov/hitech/login.action
Once there, you will need your National Plan and Provider Enumeration System (NPPES) credentials to login, and then follow directions. Once you have completed federal registration, you will be sent a letter inviting you to register at the state level in CHAMPS. This is the second part of program registration.
FAQ s Relating to State Level Registration
1) Q: How do I log into CHAMPS for EHR registration?
A: Go to https://sso.state.mi.us/ and enter your Single Sign-On User ID and Password. Select “CHAMPS.” Acknowledge/Agree, click on the “links” drop-down list (at the top right hand corner of your screen), and select “EHR MIPP.” This will allow you to begin the EHR registration process.
2) Q: What are some of the common login Issues when using CHAMPS?
A: When registering in CHAMPS, please be mindful of the following:
3) Q: How long do I have to complete registration in the Medicaid EHR Incentive Program for year 2011?
A: EPs have until 60 days after the end of the calendar year. EHs have until the end of the 2011 fiscal year.
4) Q: The welcome letter I received inviting me to register in CHAMPS states that I have 90 days from the receipt of the letter to register. Is this correct?
A: This is not applicable for the first year, but will be for year two.
5) Q: I have registered with the State, when can I expect payment?
A: Generally, Medicaid treats each registration on a first come, first serve basis. A great deal of work is spent on eligibility verification, so times may vary. Once the registration has been approved, the EP will receive an email notification. Payment should be made within two weeks of receipt of that notification. If there is a problem with an EP’s registration, state staff will contact you.
- The Domain needs to be the professional’s individual NPI.
- The Profile needs to be “Domain Administrator.”
- You must use Internet Explorer 8 or 9 (if 9, click on the compatibility mode icon).
- Most NPIs are associated with an employer Tax Identification Number (TIN)—a corporation, partnership, LLC, etc. If you registered at the Federal Level and requested that your incentive payment be sent to your SSN rather than your employer TIN, then during your state-level registration (in CHAMPS), you will receive an error message that will prevent you from continuing with registration. (You will not receive an error if your NPI is already associated with your SSN at the Michigan Department of Treasury.) To resolve the error, you must link your SSN to your NPI at the Michigan Department of Treasury website (http://www.michigan.gov/treasury/0,4679,7-121--131970--,00.html) and then return to the registration process.
- You must enter the NLR number correctly.
FAQs of a General Nature
1) Q: How much money should I expect?
A: EPs will receive $21,250 in the first year and $8,500 in each of the five years that follow, contingent on continued eligibility and satisfaction of MU requirements. The total maximum incentive is $63,750. Pediatricians with more than 20 percent but less than 30 percent Medicaid patient volume will receive two-thirds of the maximum amount. Payment amounts will vary for EHs.
2) Q: Where can I find a list of certified EHR systems?
A: A list of certified EHR systems is available through the Office of the National Coordinator for Health Information Technology at: http://onc-chpl.force.com/ehrcert.
3) Q: Can I skip a year or two in the Medicaid EHR Incentive Program, or must I participate for six consecutive years?
A: Yes, you may skip years. Keep in mind the program ends in 2021, so if you join the program in 2016 (the last year an EP can do so), only six years will remain in the program, and you will have to participate in consecutive years if you want to receive all six payments.
4) Q: Is there a limit on the number of Eligible Providers who can send their incentive payments to a single practice?
A: No, there is not.
5) Q: Can I have my incentive sent to any medical group I desire?
A: Yes, the individual EP determines where their incentive payment is sent.
6) Q: In what form does the incentive payment arrive?
A: It will come in the same form as any other payment you receive from Medicaid.
7) Q: Do I always provide meaningful use (MU) data from the previous calendar year?
A: In the second program year, when you first provide MU
data, you will provide data from a 90-day consecutive period within that same calendar year. In all years that follow, you will be reporting MU data for an entire calendar year. That will require you to actually report early in the following calendar year. For example, your MU data for 2015 will be reported in early 2016.
8) Q: What are the differences between the Medicaid and Medicare EHR Incentive Programs?
A: See the following chart for an illustration of the differences.
|Federal Government will implement (will be optional nationally)
||Voluntary for States to implement, with Michigan choosing to implement
|Payment reductions begin in 2015 for providers that do not demonstrate Meaningful Use (MU)
||No Medicaid payment reductions
|Must demonstrate MU in Year 1
||No MU requirement in Year 1, Adopt, Implement, and Upgrade option in Year 1
|Maximum incentive is $44,000 for EPs (10% bonus for Eligible Providers (EPs) in Health Professional Shortage Area)
||Maximum incentive is $63,750 for EPs
|The Requirements for MU Stage 1 are defined for Medicare
||Michigan has adopted the MU Stage 1 definition as outlined for Medicare
|Last year a provider may initiate program is 2014; Last year to register is 2016; Payment adjustment begin in 2015
||Last year a provider may initiate program is 2016; Last incentive payment in 2021
|Only physicians, subsection (d) hospitals and CAHs
||5 types of EPs, acute care hospitals, critical access hospitals and children's hospitals