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Find a list of our past EHR Incentive Program email communications at our Archived Announcements
NEW RULE ISSUED BY CMS WILL MEAN A FEW CHANGES TO PROVIDERS PARTICIPATING IN THE MEDICAID EHRIP (Posted 8/17/17)
On August 2, 2017, the Centers for Medicare & Medicaid Services (CMS) issued the IPPS final rule, which has implications for the Medicare and Medicaid Electronic Health Record Incentive Programs. The rule announces changes to Eligible Hospital CQM reporting periods for calendar year 2017 and 2018 AND Eligible Professional CQM reporting period changes for calendar year 2017. CMS has also made several other adjustments:
- The meaningful use reporting period for 2018 has been changed to 90 days
- CEHRT flexibility has been adopted for 2018
- Exceptions for Medicare payment adjustments for EH and EP have been added for those whose CEHRT has been decertified by ONC.
A detailed review of the final rule is underway, and we will be sending updates as information becomes available. This rule will be effective October 1, 2017.
PUBLIC HEALTH DOCUMENTATION AID UPDATED FOR PY2017 MODIFIED-MU2 (Posted 6/29/17)
The Public Health Documentation Aid contains screenshots of the three Public Health Meaningful Use Measures as they appear within the MAPIR attestation environment, keyed with spaces to provide additional information for the measures met or the exclusions qualified for. The Documentation Aid, when emailed or uploaded at the time of attestation along with the supporting documentation, will facilitate the application review process, and will also help provide the information that would be requested in the event of an audit:
Program Year 2017 EPs Attesting to Modified MU Stage 2
UPDATED VERMONT MEDICAID EHRIP AUDIT TIPSHEET (Posted 6/29/17)
The VT EHRIP Audit Team has updated their helpful Eligible Professional Audit Tip Sheet based on their activities and experience with reviewing provider records. Remember, the best time to prepare for an audit is during the attestation process. Download and consult this guidance as you prepare and submit your EHRIP attestation.
REMINDER: LAPSED MEDICAID ENROLLMENT CANCELS ANY ACTIVE MAPIR APPLICATION (Posted 6/29/17)
If an Eligible Professional’s Vermont Medicaid enrollment lapses at any time after an application is started and BEFORE A PAYMENT IS RECEIVED, the application will be automatically cancelled in the MAPIR system. All saved data for the application will be eliminated. The attestation must then be restarted from the beginning in MAPIR if the EP is able to be fully re-enrolled in Vermont Medicaid. If a MAPIR application of one of your providers is cancelled, please contact us right away: ahs.dvhaEHRIP@vermont.gov
THE BLUEPRINT VERMONT CLINICAL REGISTRY IS A SPECIALIZED REGISTRY (Posted 6/29/17)
Eligible Professionals at practices participating in the Vermont Blueprint for Health may use their engagement with Blueprint’s Vermont Clinical Registry to meet the Specialized Registry reporting option for the Public Health Objective. A significant number of Blueprint practices send their data through VITL’s Health Information Exchange where it then flows to the Vermont Clinical Registry. If you have any questions about whether you qualify for registering, onboarding or reporting data to this registry for meeting the measure, please do not hesitate to contact the EHRIP Team: ahs.dvhaEHRIP@vermont.gov
MEANINGFUL USE STAGE 3 (Posted 6/29/17)
Stage 3 of Meaningful Use is an option for the first time in 2017 for those providers who have upgraded their Certified EHR Systems to the 2015 Edition, or are using a combination of 2014 and 2015 CEHRT. Providers attesting with the Vermont Medicaid EHR Incentive Program in Program Year 2017 who will be meeting Stage 3 criteria will wait to start their attestations in January 2018. We will alert our program participants when MAPIR upgrades are complete and Stage 3 screens are configured with the correct options. More information about Stage 3 criteria can be found at the CMS Website: MU3 Guidance for Medicaid EHRIP.
MEETING MU IN 2017 TO AVOID CALENDAR YEAR 2018 PAYMENT ADJUSTMENTS (Posted 6/29/17)
Many thanks to our colleagues in the Pennsylvania Medical Assistance Electronic Health Record Incentive Program for this Q&A explaining the timeframe for attesting to Meaningful Use in order to avoid Payment Adjustments:
Q—Your communication indicates that Program Year 2017 will have payment adjustments applied in payment year 2018. We thought that payment adjustments were on a two-year delay from Program Year to payment year, so Program Year 2017 would impact 2019 payment adjustments. Please clarify if payment adjustments are on a one- or two-year delay?
A—This issue is very confusing indeed and we hope not to confuse you further but here goes. CMS established an alternative for providers attesting to MU for the first time in 2016 and beyond and our message only applies to those providers. You are correct that, traditionally, meeting MU in 2016 would allow providers to avoid payment adjustments in 2018 (the two year delay).
This time, however, those attesting to MU for the first time in 2016 will avoid payment adjustments in 2017. Further, if you are attesting to MU for program year 2017, for the VERY first time, you will avoid payment adjustments in 2018. So, all providers attesting to MU for the second time and beyond, in program year 2016, would still avoid the payment adjustment on a two year delay or 2018.
Also consider this, Adopt, Implement or Upgrade (AIU) does not count toward MU…so if a provider attested to AIU in program year 2016, then program year 2017 would be the provider’s first year to attest to MU and that would allow the provider to avoid 2018 payment adjustments. Keep in mind that AIU is no longer available.
EHRIP TEAM ACTIVITIES – APPLICATION APPROVALS AND PY2017 GUIDANCE (Posted 6/8/17)
Program Year 2016 Application Processing: The Vermont EHRIP Team has been very busy actively reviewing Program Year 2016 applications and following up with providers and preparers to confirm that all information is correct and that required documentation is received. As of this week, over 70% of PY2016 attestations have been reviewed, and over 55% have been approved for payment. If you have any questions about the status of your PY2016 application, do not hesitate to contact us at ahs.dvhaEHRIP@vermont.gov.
Program Year 2017 Outreach and Education: Program Year 2017 EHRIP requirements bring just a few changes: The optional availability of Stage 3 of Meaningful Use, changes to certain Modified-MU2 measures, MU and CQM reporting periods, and more. In order to ensure providers are able to leverage their maximum six years of incentive payments, the EHRIP Team is engaged in a range of outreach and education efforts for 2017 participation. We will also be offering individual phone consultation with screen sharing to step through questions particular to your providers, and the guidance available to target Meaningful Use measures. You can contact the EHRIP Team with your questions, and to schedule a consultation: ahs.dvhaEHRIP@vermont.gov
PY2017 ATTESTATION AVAILABILITY AND DEADLINES (Posted 6/8/17)
MAPIR will be upgraded to accommodate changes to the EHRIP attestation requirements for Program Year 2017. We anticipate that providers will be able to start Program Year 2017 applications in December 2017. The deadline to submit a PY2017 application will be March 31st, 2018.
Alternate Attestations: EPs who first demonstrate meaningful use in PY2017 must demonstrate Meaningful Use for a 90-day reporting period in 2017 to avoid payment adjustments in 2018. This reporting period must occur in the first 9 months of calendar year 2017, and EP must attest to Meaningful Use no later than October 1, 2017, in order to avoid the payment adjustments in calendar year 2018. Since the MAPIR upgrade will not be available by this date to accommodate Program Year 2017 attestations, EPs needing to avoid Payment Adjustments can submit an Alternate Attestation at the Medicare R&A Site. This Alternate Attestation method will NOT issue an incentive payment, but EPs may subsequently attest for a Vermont Medicaid EHRIP payment when MAPIR is ready to accept 2017 applications.
PY2017 REPORTING PERIODS (Posted 6/8/17)
Meaningful Use EHR Reporting Period - 90 Days: For all returning participants, the EHR reporting period is a minimum of any continuous 90-days between January 1 and December 31, 2017.
CQM Reporting Period: Full Calendar Year: Starting in Program Year 2017, Eligible Professionals (EPs) and Eligible Hospitals (EHs) who are returning Meaningful Use (i.e., EPs or EHs who have attested to MU in a prior Program Year), the CQM reporting period is the full calendar year, January 1 – December 31, 2017.
CQM Reporting Period Exceptions: EPs who are first-time Meaningful Use attesters in Program Year 2017 (i.e., they are in their second payment year, and they attested to Adopt/Implement/Upgrade in payment year 1.)
NOTE for exceptions: 1) The reporting period for CQMs would be any continuous 90-day period within Calendar Year 2017; and 2) The dates of the 90-day CQM reporting period may differ from the dates of the 90-day EHR reporting period.
CHANGES TO MEANINGFUL USE MEASURES IN PY2017 (Posted 6/8/17)
Stage 3 of Meaningful Use is an option for the first time in 2017, for those providers who have upgraded their Certified EHR Systems to the 2015 Edition, or are using a combination of 2014 and 20115 CEHRT. More information about Stage 3 criteria can be found at the CMS Website: MU3 Guidance for Medicaid EHRIP
Most providers will still be attesting to the Modified-MU2 criteria in Program Year 2017. However, please keep in mind that certain measures and requirements have evolved for PY2017:
Changes to Specific Objectives in Modified-MU2 in PY2017:
- Objective 0, ONC Questions: A CMS final rule effective 1/1/2017 requires the EP to attest to cooperating with ONC’s EHR system surveillance and review activities. Objective 0 in the MAPIR Meaningful Use Objective array has been added to capture this requirement. For a screenshot of the attestation questions, click here.
- Objective 1, Protect ePHI: It is acceptable for the security risk analysis (or review of the SRA) to be conducted outside the EHR reporting period; however, the analysis must be unique for each EHR reporting period, the scope must include the full EHR reporting period, and must be conducted within the calendar year of the EHR reporting period (January 1st – December 31st).
- Objective 8, Measure 2, Patient Electronic Access: For an EHR reporting period in 2017, more than 5 percent of unique patients seen by the EP during the EHR reporting period (or his or her authorized representatives) view, download or transmit to a third party their health information during the EHR reporting period.
- Objective 9, Secure Messaging: For an EHR reporting period in 2017, for more than 5 percent of unique patients seen by the EP during the EHR reporting period, a secure message was sent using the electronic messaging function of CEHRT to the patient (or the patient-authorized representative), or in response to a secure message sent by the patient (or the patient-authorized representative) during the EHR reporting period.
- Objective 10, Public Health Reporting: For an EHR reporting period in 2017, all EPs must attest to at least two measures, or document exclusions if they cannot meet one or more measures. The Alternate Exclusion for Specialty Registry reporting is not longer available (“the EP did not plan to report on special registry data, therefore the EP is able to claim an exclusion”).
PUBLIC HEALTH OBJECTIVE FOR MODIFIED-MU2 IN PY2017 (Posted 6/8/17)
- As indicated above, all EPs must attest to at least two measures, or document exclusions if they cannot meet one or more measures.
- Providers in Active Engagement to report immunization data to the Vermont Department of Health can request documentation for the measure from AHS.VDHPHMeaningfulUse@vermont.gov.
- Syndromic Surveillance data is not accepted electronically by Vermont or New Hampshire, and providers will exclude to that measure.
- Reporting to a Specialized Registry cannot be automatically excluded in 2017. Providers reporting data to the Vermont Blueprint for Health Clinical Data Registry, and New Hampshire providers engaged with the NH Cancer Registry can meet the measure by documenting their Active Engagement status.
- EPs must ensure they are following the guidance of CMS FAQ 13657 to determine if there is a specialized registry available for them, or if they should instead claim an exclusion.
- CMS has developed a Centralized Repository for Public Health Agency and Clinical Data Registry Reporting, which is one tool providers can utilize to confirm available reporting options.
Please review the detailed guidance, screenshots and Documentation Aids available at our webpage: Public Health Reporting in PY2017 for Modified-MU2.
CMS RESOURCES FOR PY2017 REQUIREMENTS (Posted 6/8/17)
- Health Information Exchange Fact Sheet
- Security Risk Analysis Tip Sheet
- Patient Electronic Access Tip Sheet
- Public Health Reporting in 2017 for Medicaid EHRIP EPs
- 2017 Payment Adjustment Fact Sheet for EPs
PROVIDERS CONCLUDING THE VERMONT MEDICAID EHRIP: WHAT’S NEXT? (Posted 6/8/17)
Congratulations to the 62 providers scheduled to complete all six years of their eligibity with the Medicaid EHR Incentive Program as of their Program Year 2016 payment! Providers finishing their incentive payments for meeting Meaningful Use in the EHRIP, please keep in mind that other quality programs still exist. For 2017 and beyond, if providers also see Medicare patients, the Merit-based Incentive Payment System will replace Medicare reporting for the Medicare EHR program, Physician Quality Reporting System and the Value-Based Payment Modifier. The Quality Payment Program is part of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) and includes two tracks — Advanced Alternative Payment Models (APMs) and the Merit-based Incentive Payment System (MIPS). If you have questions or need assistance with determining eligibility or requirements, visit the Quality Payment Program to find out if providers should participate in MIPS at https://qpp.cms.gov
VERMONT MEDICAID EHRIP REPORTS (Posted 6/8/17)
At the EHRIP Reports webpage, you will find reports that track the perfomance progress of the Vermont Medicaid EHR Incentive Program.
Payments to Eligible Providers: Lists all Eligible Hospitals and Eligible Professionals that received a Vermont Medicaid EHR Incentive Program payment for each Program Year. Each month’s update is a cumulative, full replacement for all previously posted files.
The 2016 Annual Report: A CMS-prescribed format for Federally-defined annual reporting requirements for EHR Incentive Program payments. It contains aggregate Meaningful Use (MU) and Clinical Quality Measure (CQM) data for all Medicaid EHR incentive payments made by the State of Vermont to Eligible Professionals from the program's inception through March 31, 2017.
Cumulative Payment Report: Illustrates the cumulative dollar amount of payments made to date for all Eligible Hospitals and Eligible Professionals.
An archive of previously issued VT Medicaid EHRIP Announcements is available here.
For questions, contact the Vermont EHRIP Team at ahs.dvhaEHRIP@vermont.gov
(Page last updated 08/17/2017)