Meaningful Use FAQ’s

A key element of Meaningful Use is the use of interoperable electronic health records (EHR’s) and electronic medical record systems that also connect to consumer experiences.  This includes leveraging secure messaging, patient engagement tools and health data sharing to foster a coordinate care experience between all members of the care team.

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“The Medicaid EHR Incentive Program provides incentive payments to eligible professionals, eligible hospitals, and CAHs as they adopt, implement, upgrade, or demonstrate meaningful use of certified EHR technology in their first year of participation and demonstrate meaningful use for up to five remaining participation years.”

Here are a list of questions related to MU and technology.

If I participated in the Medicaid Electronic Health Records (EHR) Incentive Program last year, am I required to participate in the following year?

No.  Medicaid providers are not required to participate in consecutive years of the EHR Incentive Program.  Providers who skip years of participation will resume the progression of Meaningful Use (MU) where they left off.  All providers are required to meet two years of Stage 1 in their first two years of MU  and then proceed to Stage 2, regardless of not participating in consecutive years.   (Note that there is an exception to that general rule for providers who demonstrated MU in 2011.  These providers need not move to Stage 2 until 2014.)

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Note that eligible professionals who wish to maximize their incentive payments must qualify for an incentive payment for six years, but they can begin receiving payments no later than 2016, and may not receive payments after 2021.  Also note that after 2016, eligible hospitals must have participated in the previous year in order to receive a payment.

For more information on what your meaningful use and incentive payment timeline will be, please see the timeline widget at
http://cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Participation-Timeline.html.

A number of measures for Meaningful Use objectives for eligible hospitals and critical access hospitals (CAHs) include patients admitted to the Emergency Department (ED). Which ED patients should be included in the denominators of these measures for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs?

There are two methods for calculating ED admissions for the denominators for measures associated with Stage 1 of Meaningful Use objectives. Eligible hospitals 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, eligible hospitals 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:

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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) Meaningful Use measure. Similarly, other actions taken within the ED would count for purposes of determining Meaningful Use.

 

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.

For more information about the Medicare and Medicaid EHR Incentive Program, please visithttp://www.cms.gov/EHRIncentivePrograms.

 

Who can enter medication orders in order to meet the measure for the computerized provider order entry (CPOE) meaningful use objective under the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs? When must these medication orders be entered?

Any licensed healthcare professional can enter orders into the medical record for purposes of including the order in the numerator for the measure of the CPOE objective if they can enter the order per state, local, and professional guidelines. 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. Each provider will have to evaluate on a case-by-case basis whether a given situation is entered according to state, local, and professional guidelines, allows for clinical judgment before the medication is given, and is the first time the order becomes part of the patient’s medical record.

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For more information about the Medicare and Medicaid EHR Incentive Program, please visithttp://www.cms.gov/EHRIncentivePrograms.

What do the numerators and denominators mean in measures that are required to demonstrate meaningful use for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Program?

There are 15 measures for EPs and 14 measures for eligible hospitals that require the collection of data to calculate a percentage, which will be the basis for determining if the Meaningful Use objective was met according to a minimum threshold for that objective.

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Objectives requiring a numerator and denominator to generate this calculation are divided into two groups: one where the denominator is based on patients seen or admitted during the EHR reporting period, regardless of whether their records are maintained using certified EHR technology; and a second group where the objective is not relevant to all patients either due to limitations (e.g., recording tobacco use for all patients 13 and older) or because the action related to the objective is not relevant (e.g., transmitting prescriptions electronically). For these objectives, the denominator is based on actions related to patients whose records are maintained using certified EHR technology. This grouping is designed to reduce the burden on providers. Table 3 in the Medicare and Medicaid EHR Incentive programs final rule (FR 75 44376 – 44380) lists measures sorted by the method of measure calculation. To view the final rule, please visit: http://edocket.access.gpo.gov/2010/pdf/2010-17207.pdf.

For more information about the Medicare and Medicaid EHR Incentive Program, please visithttp://www.cms.gov/EHRIncentivePrograms.

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

In order to receive Medicare EHR incentive payments, EPs, eligible hospitals, and critical access hospitals must have an enrollment record in PECOS with an APPROVED status. Medicaid EPs do not have to be in PECOS. It is possible to receive payment for Medicare claims and not be in approved status. We encourage all providers to verify their status as soon as possible.
There are three ways to verify that you have an enrollment record in PECOS:

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1. Check the Ordering Referring Report on the CMS website. If you are on that report, you have a current enrollment record in PECOS. Go to http://www.cms.gov/MedicareProviderSupEnroll/, click on “Ordering Referring Report” on the left.

2. Use Internet-based PECOS to look for your PECOS enrollment record. If no record is displayed, you do not have an enrollment record in PECOS. Go to http://www.cms.gov/MedicareProviderSupEnroll/, click on “Internet-based PECOS” on the left.

3. Contact your designated Medicare enrollment contractor and ask if you have an enrollment record in PECOS. Go tohttp://www.cms.gov/MedicareProviderSupEnroll/, click on “Medicare Fee-For-Service Contact Information” under “Downloads.”

If you are not in PECOS, the best way to submit your application is through internet-based PECOS.  For more information go to:http://questions.cms.hhs.gov/app/answers/detail/a_id/10038/kw/pecos/session/L3NpZC9qeG1GdDliaw%3D%3D

Indian Health Service (IHS) providers who submit a paper CMS-855 will have their enrollment information entered into PECOS.

For more information about the Medicare and Medicaid EHR Incentive Program, please visithttp://www.cms.gov/EHRIncentivePrograms.

 

[EHR Incentive Program] Will the Centers for Medicare & Medicaid Services (CMS) conduct audits as part of the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs?

Any provider attesting to receive an EHR incentive payment for either the Medicare or Medicaid EHR Incentive Program potentially can be subject to an audit. Here’s what you need to know to make sure you’re prepared:
Overview of the CMS EHR Incentive Programs Audits
• All providers attesting to receive an EHR incentive payment for either the Medicare or Medicaid EHR Incentive Programs should retain ALL relevant supporting documentation (in either paper or electronic format) used in the completion of the Attestation Module responses.  Documentation to support the attestation should be retained for six years post-attestation. Documentation to support payment calculations (such as cost report data) should continue to follow the current documentation retention processes.
• CMS, and its contractors, will perform audits on Medicare and dually-eligible (Medicare and Medicaid) providers.
• States, and their contractors, will perform audits on Medicaid providers.
• CMS and states will also manage appeals processes.
Preparing for an Audit
• To ensure you are prepared for a potential audit, save the electronic or paper documentation that supports your attestation. Also save the documentation that supports the values you entered in the Attestation Module for Clinical Quality Measures (CQMs). Hospitals should also maintain documentation that supports their payment calculations.
• Upon audit, the documentation will be used to validate that the provider accurately attested and submitted CQMs, as well as to verify that the incentive payment was accurate.
Details of the Audits
• There are numerous pre-payment edit checks built into the EHR Incentive Programs’ systems to detect inaccuracies in eligibility, reporting, and payment.
• Post-payment audits will also be completed during the course of the EHR Incentive Programs.
• If, based on an audit, a provider is found to not be eligible for an EHR incentive payment, the payment will be recouped.
• CMS has an appeals process for eligible professionals, eligible hospitals, and critical access hospitals that participate in the Medicare EHR Incentive Program.
• States will implement appeals processes for the Medicaid EHR Incentive Program. For more information about these appeals, please contact your State Medicaid Agency.
What information should an eligible professional, eligible hospital, or critical access hospital participating in the Medicare or Medicaid Electronic Health Record (EHR) Incentive Programs maintain in case of an audit?
An audit may include a review of any of the documentation needed to support the information that was entered in the attestation. The level of the audit review may depend on a number of factors, and it is not possible to include an all-inclusive list of supporting documents.
The primary documentation that will be requested in all reviews is the source document(s) that the provider used when completing the attestation. This document should 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.
Although the summary document is the primary review step, there could be additional and more detailed reviews of any of the measures, including review of medical records and patient records. The provider should be able to provide documentation to support each measure to which he or she attested, including any exclusions claimed by the provider.
A few examples of additional support are as follows:
• Drug-Drug/Drug-Allergy Interaction Checks and Clinical Decision Support – Proof that the functionality is available, enabled, and active in the system for the duration of the EHR reporting period.
• Electronic Exchange of Clinical Information – Screenshots from the EHR system or other documentation that document a test exchange of key clinical information (successful or unsuccessful) with another provider of care. Alternately, a letter or email from the receiving provider confirming the exchange, including specific information such as the date of the exchange, name of providers, and whether the test was successful.
• Protect Electronic Health Information – Proof that a security risk analysis of the certified EHR technology was performed prior to the end of the reporting period (e.g., report which documents the procedures performed during the analysis and the results).
• Drug Formulary Checks – Proof that the functionality is available, enabled, and active in the system for the duration of the EHR reporting period.
• Immunization Registries Data Submission, Reportable Lab Results to Public Health Agencies, and Syndromic Surveillance Data Submission– Screenshots from the EHR system or other documentation that document a test submission to the registry or public health agency (successful or unsuccessful). Alternately, a letter or email from registry or public health agency confirming the receipt (or failure of receipt) of the submitted data, including the date of the submission, name of parties involved, and whether the test was successful.
• Exclusions – Documentation to support each exclusion to a measure claimed by the provider.
For Medicare eligible professionals and for hospitals that are eligible for both Medicare and Medicaid EHR incentive payments – When a provider is selected for an audit, they will receive an initial request letter from the audit contractor. The request letter will be sent electronically by the audit contractor from a CMS email address and will include the audit contractor’s contact information. The email address provided during registration for the EHR Incentive Program will be used for the initial request letter.
The initial review process will be conducted at the audit contractor’s location, using the information received as a result of the initial request letter. Additional information might be needed during or after this initial review process, and in some cases an on-site review at the provider’s location could follow. A demonstration of the EHR system could be requested during the on-site review. A secure communication process has been established by the contractor, which will assist the provider to send any information that could be considered sensitive. Any questions pertaining to the information request should be directed to the audit contractor.
States will have separate audit processes for their Medicaid EHR Incentive Program. For more information about these audit processes, please contact your State Medicaid Agency.

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[EHR Incentive Programs] Can attestation information submitted for the Electronic Health Records (EHR) Incentive Programs be updated, changed, cancelled or withdrawn after successful submission in the EHR Registration and Attestation System?

Once a provider has submitted their attestation and has been either locked for payment or had an incentive payment issued, they will not have the ability to amend the information in the attestation system.  It is the provider’s responsibility to maintain records that demonstrate they have met meaningful use requirements and determine whether corrections to their attestation information would enable them to continue to demonstrate meaningful use.

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If the provider is not able to demonstrate meaningful use with the amended data, it is the provider’s responsibility to complete the Medicare EHR Incentive Program Return Payment/Withdrawal Form and follow the instructions on the form explaining how to return their EHR incentive payment.   Further instructions on the steps necessary to withdraw an attestation from the EHR Incentive Program can be found on the Medicare Incentive Payment Withdrawal Form.

Medicare Incentive Payment Withdrawal Form:
https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/Medicare_EHR_Incentive_Withdrawal_Final.pdf.

Providers may access the online Meaningful Use Attestation Calculator tool found at www.cms.gov/apps/ehr to enter their amended data and test whether they would continue to demonstrate meaningful use.

An EP or hospital wishing to change or withdraw their attestation from a Medicaid EHR Incentive Program should contact their state directly to make this request.

Please note that the Centers for Medicare and Medicaid Services (CMS) do not require providers who relied on flawed software for their attestation information to submit amended attestation data.  For additional information, please see FAQ#6097.

 

How can a health care provider apply for and obtain a National Provider Identifier (NPI)?

A health care provider may apply for an NPI in one of three ways:

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1. Apply through a web-based application process. The web address to the National Plan and Provider Enumeration System (NPPES) is https://nppes.cms.hhs.gov.

2. If requested, give permission to have an Electronic File Interchange Organization (EFIO) submit the application data on behalf of the health care provider (i.e., through a bulk enumeration process). If a health care provider agrees to permit an EFIO to apply for the NPI, the EFIO will provide instructions regarding the information that is required to complete the process.

3. Fill out and mail a paper application form to the NPI Enumerator.  Health care providers may wish to obtain a copy of the paper NPI Application/Update Form (CMS-10114) and mail the completed, signed application to the NPI Enumerator located in Fargo, ND, whereby staff at the NPI Enumerator will enter the application data into NPPES.  This form is now available for download from the CMS website (http://www.cms.gov/cmsforms/downloads/CMS10114.pdf) or by request from the NPI Enumerator.  Health care providers who wish to obtain a copy of this form from the NPI Enumerator may do so in any of these ways:

Phone:  1-800-465-3203 or TTY 1-800-692-2326
E-mail:  customerservice@npienumerator.com
Mail:
NPI Enumerator
P.O. Box 6059
Fargo, ND  58108-6059

How and when will incentive payments for the Medicare Electronic Health Record (EHR) Incentive Programs be made?

For eligible professionals (EPs), incentive payments for the Medicare EHR Incentive Program will be made approximately eight to twelve weeks after an EP successfully attests that they have demonstrated meaningful use of certified EHR technology. However, EPs will not receive incentive payments within that timeframe if they have not yet met the threshold for allowed charges for covered professional services furnished by the EP during the year. Payments will be held until the EP meets the threshold in allowed charges for the calendar year ($24,000 in the EP’s first year) in order to maximize the amount of the EHR incentive payment they receive. Medicare EHR incentive payments are based on 75% of the estimated allowed charges for covered professional services furnished by the EP during the entire calendar year. If the EP has not met the threshold in allowed charges by the end of calendar year, CMS expects to issue an incentive payment for the EP in March of the following year (allowing two months after the end of the calendar year for all pending claims to be processed).

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Payments to Medicare EPs will be made to the taxpayer identification number (TIN) selected at the time of registration, through the same channels their claims payments are made. The form of payment (electronic funds transfer or check) will be the same as claims payments.

Bonus payments for EPs who practice predominantly in a geographic Health Professional Shortage Area (HPSA) will be made as separate lump-sum payments no later than the end of the calendar year following the year in which the EP was eligible for the bonus payment.
Medicare EHR incentive payments to eligible hospitals and critical access hospitals (CAHs) will also be made approximately four to eight weeks after the eligible hospital or CAH successfully attests to having demonstrated meaningful use of certified EHR technology. Eligible hospitals and CAHs will receive an initial payment and a final payment. Final payment will be determined at the time of settling the hospital cost report. CAHs will be paid after they submit their reasonable cost data to their Medicare Administrative Contractor (MAC).

Please note that the Medicaid incentives will be paid by the States, but the timing will vary according to State. Please contact your State Medicaid Agency for more details about payment.

For more information about the Medicare and Medicaid EHR Incentive Program, please visithttp://www.cms.gov/EHRIncentivePrograms.

How long after the October 1, 2014 ICD-10 compliance date must I continue to report and/or process ICD-9 codes?

Each payer determines their late filing requirements for standard transactions and ICD-10 does not require a change to these requirements.  These deadline requirements vary among plans.  Contact your payer for the current information regarding late filing for claims. 

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How do I report ICD-10 codes on claims when the dates of service span from prior to 10/1/2014 to on or after 10/1/2014?

Many payers are requiring claims with dates of service that span the October 1, 2014 implementation date to be split so that the services prior to 10/1/2014 are billed separately and utilize ICD-9 codes; services on and after 10/1/2014 are billed separately and utilize ICD-10 codes.

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Check specific payer guidelines for processing claims for services that span the 10/1/2014 ICD-10 transition date.

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