FAQ

FAQ

 

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:

  • Physicians (MD and DO)
  • Nurse Practitioners
  • Certified Nurse-Midwifes
  • Dentists
  • Physician Assistants (PA) practicing in a PA-led FQHC or a PA-led Rural Health Clinic (RHC)
  • Optometrists (OD)

2) Q: What Medicaid patient volume thresholds do I need to meet in order to participate in the Michigan Medicaid EHR Incentive Program?
A: To qualify for an incentive payment under the Medicaid EHR Incentive Program, an EP must meet one of the following criteria:

  • Have 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
  • If you practice predominantly in a Federally Qualified Health Center or Rural Health Center, have a minimum 30% patient volume based on Medicaid encounters and encounters attributable to needy individuals

You are also encouraged to complete the Annual Eligibility Worksheet, available here:

EP Eligibility Worksheet 2013

3) Q: What is a Medicaid encounter? What is a patient encounter?

A: For the purpose of calculating EP patient volume, a Medicaid encounter occurs when an EP provides a medical service to a Medicaid enrolled patient on a date falling within the 90-day eligibility reporting period. This includes certain “zero-pay” encounters. See the “EP’s Guide to the Michigan Medicaid EHR Incentive Program” for more details. A patient encounter in general, which would be included in the denominator of the patient volume calculation, is defined as a medical service rendered to an individual on a date falling within the 90-day eligibility reporting period.

Note: Multiple claims for the same patient, on the same day, count as only one encounter for each rendering EP. This also means that for EPs using the group proxy option for eligibility, a service provided by multiple providers in the same group for the same patient on the same day may only count as one encounter for the group.

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?
A: Yes. Please refer to “The EP’s Guide to the Michigan Medicaid EHR Incentive Program” for details.

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:

  • 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.

For additional information please refer to the EP Guide:
https://michiganhealthit.org/wp-content/uploads/EP-Guide-3.7-7-10-2014.pdf

7) Q: What if I did not have an EHR last year; 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, for example, if you wish to register in 2013, you can do so even if you did not have a certified system during the 90-day period you are using for your 2012 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: 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.

  • 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)

11) Q: Is qualifying patient volume always determined from a consecutive 90-day period in the previous calendar year?
A: Beginning with Program Year 2013 (Calendar Year 2013 for EPs), the consecutive 90-day period may be chosen from EITHER the previous calendar year OR from the 12-month period immediately prior to attestation. For example, a provider attesting on July 1, 2013 could select a 90-day period within the range January 1, 2012 to December 31, 2012, OR any 90-day period from July 1, 2012 to July 1, 2013.

12) Q: Can I use the same 90-day eligibility reporting period in two consecutive payment years?
A: No. With the new options for selecting a 90-day eligibility reporting period (see FAQ #12 above), this would be theoretically possible as illustrated in the following example:

“A provider attests in January 2014 for the reporting period of Oct.-Dec 2013 and selects a 90-day eligibility reporting period under the previous 12 months option: July-Sept 2013. The provider’s 2014 90-day Meaningful Use reporting period is Jan-March 2014, and the provider attests in April 2014 using the same July-Sept 2013 eligibility reporting period under the previous calendar year option.”

However, the provider is expected to maintain Medicaid Patient Volume eligibility from program year to program year and thus must choose a later reporting period for each year in the program.

13) Q: We are registering under the group proxy option with one Tax ID number (TIN). Do we need to include all Group NPIs associated with that TIN?
A: Yes. All Group NPIs under the TIN must be included in a proxy. The only exception is for Group NPIs representing hospital-located outpatient clinics.

14) Q: I am registering using the group proxy option, but I’m new to the practice and only in my Adopt, Implement, Upgrade (AIU) first year. The rest of the providers here are already reporting on Meaningful Use. Should I wait to register until they finish their MU reporting period?
A: No, you do not have to wait for those doing Meaningful Use to attest. You must use the same eligibility numbers, however.

15) Q: We are a practice that has not attested yet for the Medicaid EHR Incentive Program. We plan to use a group proxy option, but we recently had a new EP join the practice. This EP was not part of the practice during the eligibility reporting period from the previous calendar year that we will be using for our proxy. Can we still attest for this physician and count him/her as part of the group proxy?
A: Yes. Especially in the case of EPs new to the practice of medicine, a group proxy may include EPs who join after the proxy reporting period has ended, but BEFORE the group attests for Adopt, Implement, Upgrade or Meaningful Use.

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 should it 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.

FAQs Relating to State Level Registration

1) Q: How do I log into CHAMPS for EHR registration?
A: Go to https://milogintp.michigan.gov. After signing on to MILogin, you will need to enter into CHAMPS. Read the “Terms & Conditions” Pop-Up window, and if you “Acknowledge/Agree”, click the corresponding button. Chose the provider you would like to register, chose “Domain Administrator” and click the “Go” button. In the next window, click 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:

  • 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 CMS registration number correctly.

3) Q: How long do I have to complete registration in the Medicaid EHR Incentive Program for a given program year?
A: EPs have until 60 days after the end of their program year, which is a calendar year. EHs have until the end of their appropriate fiscal year. For example, for program year 2013, EPs would have until March 1, 2014, while EHs would have until September 30, 2013, the end of Federal Fiscal Year 2013.

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: In your first year of the Medicaid EHR Incentive Program, you have 90 days from the date on the letter, which is the same as when you successfully complete your federal level registration, to initiate registration at the State level in CHAMPS. If you do not initiate the state level registration within those 90 days, you will be automatically denied back to the National Level Repository. Lack of activity for 90 days will also result in an automatic denial back to the NLR. There is no auto-deny for Year 2 or beyond in the Michigan Medicaid EHR Incentive Program.

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.

6) Q: I have registered with the State, when can I expect payment?
A: Please first consult the State Level Registration Guide, available at: https://michiganhealthit.org/wp-content/uploads/EP-State-level-Registration-Guide.pdf. If this is insufficient to answer your question, contact the CHAMPS Provider Hotline at 1-800-292-2550.

7) Q: What is this survey at the end of the registration process?
A: The EHR Incentive Program survey is how the Michigan Medicaid EHR Incentive Program keeps track of the progress of EHR adoption in the state, and identifies any barriers to adoption or Meaningful Use. Be sure that when you complete the survey, click “Register” to finish the State Level Registration Process. If you are registering under the group proxy option, inputting a Group NPI will generate only one survey for the group, so there doesn’t need to be one filled out for each individual provider.

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 (i.e., $14,500 in the first year or $5,667 in any of the following 5 years). 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. Be aware that if you are using the group proxy option, you may receive one large lump sum adjustment that contains the sum of all payments.

7) Q: Why did I not receive my full incentive payment?
A: Medicaid may deduct any outstanding claim adjustments from incentive payments to providers who owe Medicaid money. Pediatricians who fail to meet the 30% Medicaid Patient Volume threshold but meet a 20% Medicaid Patient Volume threshold will receive 2/3 the amount of the incentive payment.

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.

Medicare Medicaid
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 6 types of EPs, acute care hospitals, critical access hospitals and children’s hospitals

9) Q: I am a resident physician. Can I qualify for the Medicaid EHR Incentive Program?
A: Yes. If you meet all of the eligibility requirements (see the “EP’s Guide to the Michigan Medicaid EHR Incentive Program” for details), you may qualify for the Michigan Medicaid EHR Incentive Program.

FAQs Relating to Meaningful Use (MU) Reporting

1) 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.

2) Q: What is Stage 2 Meaningful Use?
A: If you have attested under Adopt, Implement, Upgrade (AIU) and have completed two years of Stage 1 Meaningful Use reporting, you will pass on to Stage 2 of Meaningful Use. Meeting Stage 2 will require passing 17 Core Objectives (up from 15) and choosing any 3 of 6 Menu Objectives. Some of the measures for these objectives will be the same as in Stage 1, but with a higher threshold for passing. Providers who attested for AIU in 2011 and Stage 1 MU in 2012 and 2013 will begin Stage 2 in 2014. For more information about Stage 2 requirements, visit:

http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Stage_2.html

3) Q: What is the difference between 2011 and 2014 ONC Certified EHR Technology?
A: To hold EHR vendors to higher standards to enable providers to meet Stage 2 Meaningful Use, the Office of the National Coordinator for Health Information Technology (ONC) released regulations for 2014 Certified EHR Technology. ALL PROVIDERS BEYOND THE AIU YEAR, REGARDLESS OF STAGE OF MEANINGFUL USE, MUST USE 2014 CERTIFIED EHR TECHNOLOGY TO MEET MEANINGFUL USE IN 2014 AND BEYOND. The ONC also adjusted the certification requirements so that EPs will only need to have those EHR functions that will enable them to meet Meaningful Use requirements. (For example, a dentist will not need an EHR that is certified for measures regarding immunizations.) In 2013, providers that still have 2011 Certified EHR Technology can still use it to meet Meaningful Use requirements. For more information on 2014 CEHRT, visit:

http://www.healthit.gov/policy-researchers-implementers/meaningful-use-stage-2

4) Q: How am I supposed to upgrade to a new EHR AND meet the Meaningful Use requirements for a full year in 2014?
A: Because of the required upgrade to 2014 ONC Certified EHR Technology for ALL PROVIDERS IN ALL STAGES OF MEANINGFUL USE, CMS is allowing all providers in all stages of MU to report only one 3-month period of Meaningful Use*. Since this period must be the same as the Clinical Quality Measures (CQM) reporting period, and since Michigan intends to receive CQMs electronically, both Medicare and Medicaid* EPs must select a calendar quarter in 2014 (i.e.; Jan.-Mar. 2014; Apr.-June 2014; July-Sept. 2014; Oct.-Dec. 2014) to report both Meaningful Use and CQMs. Eligible Hospitals and Critical Access Hospitals must select a calendar quarter in FFY 2014 (i.e., Oct.-Dec. 2013; Jan.-Mar. 2014, Apr.-June 2014; July-Sept. 2014) for this reporting.

*For Medicaid and Medicare EPs in their first year of MU, they will still be able to select any 90-day period in 2014 as usual, since they are not required to automatically electronically submit their CQMs.

IMPORTANT: Be sure that you are able to recover data from your 2011 Certified EHR to establish your eligibility and in the event of an audit.

4.c) Q: Does my practice qualify for exclusion to the meaningful use objective of capability to submit electronic data to syndromic surveillance information systems? 

A: MDCH has determined MSSS (Michigan Syndromic Surveillance System) has the capacity to receive syndromic data in accordance with the established meaningful use vocabulary and content exchange standards for eligible hospital emergency departments, urgent care centers, and certain ambulatory care providers (Eligible Professionals or EPs). MSSS can receive syndromic data from EPs as of August 1, 2013. Therefore, eligible professionals that are required to report syndromic data according to meaningful use objectives do not, in general, qualify for exclusion to the meaningful use objective for the reason the state does not have the capability to accept syndromic data electronically. Furthermore, eligible hospitals that are required to report syndromic data according to meaningful use objectives do not qualify for exclusion to the meaningful use objective for the reason the state does not have the capability to accept syndromic data electronically. Since MSSS will not be receiving inpatient data, Eligible Hospitals that have no emergency department may claim an exclusion from the Syndromic Objective, if they do not also administer immunizations or report lab results to the Michigan Department of Community Health.

Please note: The MSSS Testing and Submission Guide lists those EPs from which MSSS will and will not accept electronic syndromic data.

If an EP is in Stage 1 Meaningful Use:
Only EPs from whom the State of Michigan does not accept MSSS messages (listed as “No” in the MSSS Guide) may claim exclusion from one of the Public Health Measures (Menu Measures 9 and 10 for Stage 1 of Meaningful Use) if they also do not administer immunizations. EPs listed as “No” in the MSSS Guide that do not administer immunizations should claim the exclusion for Stage 1 Menu Measure 9 (Immunizations) only.

If an EP is in Stage 2 Meaningful Use:
In Stage 2, Immunization Reporting becomes a Core Objective, and there are no requirements surrounding the selection of Public Health Reporting Menu Objectives. Therefore, EPs listed as “No” in the Guide may claim the exclusion for Stage 2 Menu Objective 1 (Syndromic Surveillance), regardless of administration of Immunizations.

5) Q: What supporting documentation should I maintain to validate that 50% of my encounters are at a site(s) with Certified Electronic Health Record Technology (CEHRT) and that at least 80% of patient records are maintained in that same CEHRT?

A: CMS requires that these thresholds be met as one of the components of achieving meaningful use. The State of Michigan collects this information within the state level registration by asking providers to fill in the following information:CMS Location Information Screenshot
Note: Providers will need to manually add any patients to the denominator that are maintained outside of the CEHRT. Once the numerator and denominator are determined, simply divide the two and record the result in the text box.

The % of encounters in locations equipped with CEHRT should be derived in the following manner:

  • Numerator – Total number of encounters recorded in CEHRT during the reporting period at each location (excluding POS codes 21 and 23) where the provider practices.
  • Denominator – Total encounters from the reporting period at each location (excluding POS codes 21 and 23) where the provider practices (recorded in the EHR as well as outside the EHR).

Note: The numerator and denominator may match what was used for eligible patient volume assuming all CEHRT locations used for patient volume qualification are the same locations used for MU. Once the numerator and denominator are determined, simply divide the two and record the result in the text box.

Providers should maintain documentation to support their numerator / denominator calculations preferably with as much documentation directly out of the CEHRT as possible. The documentation should also identify the provider by name or NPI, as well as the time period covered for the calculations (the time period should match the EHR reporting period identified in the state level registration).

FAQs Relating to Clinical Quality Measures (CQM) Reporting

1) Q: Does Michigan have any plans to allow electronic CQM reporting, or will attestation remain the only option?
A: Michigan intends to receive CQMs electronically via DIRECT messaging using the Quality Reporting Document Architecture Category Three (QRDA III) format. This capability is expected to be in place sometime in 2014. Note that only EPs in their second year of Stage 1 MU or beyond will be required to report electronically.

2) Q: I have to put 0 for the denominator of some of my CQMs. Is this allowed?
A: Yes. Please refer to CMS FAQ 2773 for details: https://questions.cms.gov/faq.php?id=5005&faqId=2773

3) Q: What CQMs will I have to report in 2014?
A: ALL PROVIDERS IN ALL STAGES OF MEANINGFUL USE must report from a new set of CQMs beginning in 2014. Where before, you had to report on 3 Core CQMs and 3 Menu CQMs, you must now report on any 9 out of a set of 64 CQMs. These 64 CQMs are divided among 6 Quality Domains; you must report at least 1 CQM from at least 3 of the 6 domains. CMS has developed a Recommended Core Set of CQMs for both EPs who primarily treat children and EPs who primarily treat adults. This Recommended Core Set is not mandatory, but has been structured to allow EPs to meet the above requirements more easily. For more information on 2014 CQMs, visit:

http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/2014_ClinicalQualityMeasures.html

4) Q: What is the difference between Stage 1 and Stage 2 CQMs?
A: NONE. ALL PROVIDERS IN ALL STAGES OF MEANINGFUL USE report using the 2011 CQM criteria through Program Year 2013, and report using the 2014 CQM criteria beginning in Program Year 2014. This is similar to the distinction between 2011 and 2014 Certified EHR Technology; there are no “Stage 1” or “Stage 2” CQMs, and there is no such thing as “Stage 1 Certified” or “Stage 2 Certified” EHR Technology.