MACRA/MIPS, 2016 Registrations and Alternate Medicare MU Attestation

MACRA/MIPS:

The Medicaid EHR incentive program is slated to continue as planned through 2021. MACRA/MIPS only sunsets the Medicare EHR Incentive Program.

Providers wishing to participate in MACRA/MIPS and the Medicaid EHR Incentive Program will need to report separately to BOTH programs.

2016 Registrations for the Medicaid EHR Incentive Program:

2016 is the final year that Eligible Professionals (EPs) and Eligible Hospitals (EHs) can register for the Medicaid EHR Incentive Program to receive incentives. All providers wishing to participate must register with CMS prior to the CMS attestation tail period close date of February 28, 2017.

EHs must attest to consecutive years in order to continue to participate with the Incentive Program. If an EH does not participate during one of the program years, they will not be able to continue in the program and forfeit all available incentive payments from future program years.

EPs who begin program participation in 2016 need to participate in all of the remaining program years (2016-2021) to capture all 6 years of incentive payments. If an EP who begins program participation in 2016 does not participate during one of the program years, they forfeit that year of participation, but can continue to participate in subsequent years.

All providers attesting to Meaningful Use (MU) for program year 2016 will attest to a MU reporting period of 90-366 days and a CQM reporting period of 90-366 days.

Providers attesting to their second through sixth year of MU will not be able to attest until after the OPPS final rule, that reduced their reporting period to a minimum of 90 days, becomes effective on January 1, 2017.

All 2016 Medicaid MU program registrations need to be submitted to the State of Michigan before the close of the Medicaid EHR Incentive Program attestation tail period on March 1, 2017 at 11:59 PM.

2016 Alternate Medicare MU Attestations:

Medicaid EHR Incentive Program participants who do not qualify to attest to MU with the State’s Medicaid EHR Incentive Program for 2016, may attest to MU by submitting a 2016 Alternate Medicare MU Attestation with Medicare in order to avoid payment adjustments in 2017 (for 1st-time MU attesters in program year 2016) or in 2018 (for returning MU attesters in program year 2016).

Please see the following link for additional information, https://michiganhealthit.org/wp-content/uploads/Alternate-Medicare-Attestation-Guide.pdf.

Medicaid EPs must complete ALL of the following steps PRIOR to the closing of CMS’s attestation tail period of February 28, 2017:

  1. Register with CMS via the CMS Registration & Attestation system at https://ehrincentives.cms.gov/hitech/login.action
  2. Have their registration confirmed by the State of Michigan’s Medicaid EHR Incentive Program. (This confirmation is an automated process but may take up to 48 hours)
  3. After registration (at CMS) and confirmation (by the State), a Medicaid EP can proceed with submitting the “Alternate Medicare MU attestation”.