Those preparing and submitting applications for incentive payments in the Medicaid Promoting Interoperability Program MUST be cognizant of whether the providers they are preparing applications for practice at other locations or have other employers.
We recommend that preparers flag any provider who either:
• Practices at another location (in most instances when it is the same employer that has multiple practice sites, the CEHRT automatically combines the data, so there will likely be no extra steps needed).
• Has more than one employer.
For each of these providers, you should confirm that at least 50% of their total outpatient encounters during their EHR reporting period took place at a location, or a combination of locations, with certified EHR technology (CEHRT).
Meaningful use measures can be calculated across locations and employers by adding the numerators and denominators from each CEHRT.
Please be advised that you will be putting your organization at risk of recoupment during post-payment audit if you do not consider all of the locations and employers of your attesting Providers. Furthermore, please be aware of the dates you are entering in your applications. The EHR Reporting Period should be used when completing the MU General Requirements section of the MAPIR attestation, not the Patient Volume dates.
Please refer to CMS guidance on multiple locations for further information: Guide for Eligible Professionals in the Medicaid Promoting Interoperability Program Practicing in Multiple Locations.
For questions, contact the Vermont PIP/EHRIP Team at ahs.dvhaEHRIP@vermont.gov
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(Page last updated 11/05/2020)