Eligibility and Application
Why are the milestone payments in each program track a fixed amount rather than a reimbursement of actual costs?
The MDAAP is funded as an incentive program. Unlike a grant program in which participants apply for and receive grant dollars based on actual expected costs, an incentive program must define up front how much each participant will receive as a fixed amount regardless of actual costs incurred. As part of the program’s design, much research and consideration went into determining the fixed incentive amounts within each program track. Participating providers that demonstrate achievement of a program milestone are entitled to the full amount of the associated incentive payment even in situations where costs incurred by the provider are less than the incentive payment.
How do I know if I am an eligible provider type?
Eligible providers are broadly defined as Medicaid-enrolled Home and Community Based Services (HCBS) providers in Vermont. Your individual or organizational Medicaid provider type and provider specialty code will determine if you are an eligible provider type to participate. If your provider type and provider specialty code appears in the table here, then you meet the eligible provider type criterion. (Note: Any providers who received incentive payments under the Promoting Interoperability Program are not eligible to participate in MDAAP.)
When calculating Medicaid patient volume, is it permissible to round up to 20% to meet eligibility if patient volume is greater than 19% but less than 20%?
Since the Medicaid volume calculation for MDAAP purposes requires the application of a State Adjustment Factor of 0.9763, which will result in non-whole numbers, Medicaid patient volume of at least 19.5% can be rounded up to 20% to meet the Medicaid volume requirement.
Should I only include encounters where Medicaid was the primary payer to calculate my Medicaid percentage for MDAAP eligibility?
Any patient who was enrolled in Medicaid at the time the billable service was provided should be included in your count of Medicaid encounters. This includes situations in which Medicaid is the primary or secondary payer and even situations where Medicaid did not pay for any portion of the encounter so long as the patient was enrolled in Medicaid at the time the service was rendered.
What type of patient encounters should be included on the patient volume spreadsheet to accurately document my Medicaid patient volume?
All patient encounters that took place within a solo provider or group practice’s selected 90-day period should be populated in the patient volume spreadsheet. This includes Medicaid-eligible encounters as well as any self-pay or commercial insurance encounters.
What is the purpose of the Unique Patient ID in the patient volume spreadsheet?
Since it is likely that a provider will have seen the same patient for multiple encounters within the provider’s selected 90-day period, it is important that every patient be identified with a unique identifier. Please do not use a patient’s name or any other form of protected health information (PHI) for this unique identifier.
An EHR vendor I am evaluating states they are “HIPAA compliant,” but they do not have HITRUST certification or 2015 Edition CEHRT status through the Office of the National Coordinator for Healthcare IT. Can their solution still be eligible for MDAAP under Program Tracks 2 or 4?
No, only EHR solutions that are 2015 Edition CEHRT and/or HITRUST certified will qualify for implementation incentives under MDAAP, as these certifications ensure the vendor is following industry standards for electronic security of health records data.
What happens if I start a program track and am unable to meet all the milestones? Am I required to meet all milestones in my specified track in order to participate?
Achievement of milestones in all program tracks is voluntary, and it is permissible to even skip milestones after getting started in a program track. However, in completing the Participation Agreement (PA), providers are committing, at a minimum, to begin engagement with the MDAAP technical assistance/program support team within the time specified within the Provider Agreement to complete a Needs Assessment. If a provider signs the MDAAP Participation Agreement and subsequently determines for any reason that they cannot engage with the MDAAP technical assistance/program support team, the provider can return their initial incentive payment using the Incentive Payment Return Form. However, in these circumstances, we recommend that the provider first reach out to the MDAAP team to determine if an additional grace period may be warranted if the provider still wishes to participate in MDAAP.
What documentation will I be required to submit to participate in the program?
All program enrollees will complete a Participation Agreement that outlines basic program expectations and a Scope of Services Agreement that details the specific assistance the business support team will offer in helping participants achieve the milestones within their selected program track.
At the time of program enrollment, a pre-screening review will be conducted to validate that an individual or organizational participant is one of the eligible Medicaid provider types and provider specialty types and is an active Vermont Medicaid provider, verified via Medicaid ID. For participants enrolling as an eligible group, a complete set of billing NPIs and Medicaid IDs across all the client service programs defining the group must also be provided. Additionally, all participants will be required to submit their Medicaid patient volume documentation, which will also be verified as part of the pre-screening review.
The documentation required for milestone attestation differs for each program track. The table here contains details on the milestone documentation required for each track. Additionally, the State will perform post-payment audits for program integrity purposes, and if selected for audit, a participant must supply all appropriate documentation to support program eligibility requirements and each milestone attestation. Therefore, it will be vitally important to maintain all documentation needed to support your Medicaid patient volume and achievement of each milestone for a period of six (6) years. This includes supporting documentation such as the Medicaid patient volume file, a copy of the executed agreement with the EHR vendor (if applicable for your chosen program track), documentation of the EHR vendor’s 2015 Edition CERHT or HITRUST certification status, documentation of completed Security Risk Assessment, etc.
If an eligible provider or provider organization recently implemented an EHR system prior to the launch of MDAAP, is it still eligible for program incentives?
An eligible provider/organization may participate and receive program incentives for EHR purchase under Track 1 or Track 2 if an eligible EHR system was purchased on or after October 1, 2022. All milestone documentation requirements for Track 1 and Track 2 still apply in situations where an eligible EHR system was purchased prior to the official launch of MDAAP.
If an eligible provider or provider organization recently established connectivity with VHIE prior to the launch of MDAAP, is it still eligible for program incentives?
An eligible provider/organization that utilizes an ONC-certified EHR (CEHRT) system may participate and receive program incentives by achieving milestones defined under Track 3 if at least one of the following scenarios apply:
- If the eligible organization is an existing Designated Agency or Specialized Service Agency and they signed a Vermont Health Information Exchange (VHIE) Service Agreement for 42 CFR Part 2 Data on or after October 1, 2022.
- If the eligible provider/organization executed a vendor contract to implement an Admit, Discharge, Transfer (ADT) interface for their CERHT system to the VHIE on or after October 1, 2022.
- If the eligible provider/organization executed a vendor contract to implement a Continuity of Care Document (CCD) interface for their CERHT system to the VHIE on or after October 1, 2022.
An eligible provider/organization that utilizes a non-CEHRT electronic program-eligible system (“EHR Lite”) may participate and receive program incentives by achieving milestones defined under Track 4 if the eligible provider/organization executed a vendor contract for connecting their non-CEHRT system to the VHIE on or after October 1, 2022.
Are any providers who practice outside the state of Vermont eligible to participate in MDAAP?
Eligible providers must have at least one clinical location within the State of Vermont, used in the calculation of patient volume where the provider is participating in MDAAP, which is using or intends to use Certified EHR Technology (CEHRT) or other HIT systems that have been approved for and meet the requirements of the MDAAP.
How long will MDAAP incentives be available?
The last date to submit an MDAAP application, which includes the completion of a Participation Agreement to fulfil your first program milestone, is September 15, 2025. The deadline for all subsequent milestone attestation is December 1, 2025.
What are the steps to initiate the application process?
Providers interested in applying should fill out and submit the form here. Upon receipt of your email request, the MDAAP team will follow-up via secure email with instructions on how to complete an attached application form. The MDAAP team can also provide support and assistance to providers in helping identify the most appropriate program track and answering any questions about completing the application, such as providing guidance on calculating Medicaid patient volume.
Participants with questions about the program can also send inquiries to ahs.dvhamdaap@vermont.gov
VHIE Data Sharing
VHIE Data Sharing FAQs for Mental Health Providers Participating in MDAAP
What is VITL?
VITL is an independent, non-profit organization that shares health data responsibly to help providers care for their patients. VITL is designated by the Vermont legislature to operate the Vermont Health Information Exchange.
What is the Vermont Health Information Exchange?
The VITL securely manages health records in one place – the Vermont Health Information Exchange (VHIE). Most Vermonters have a health record in the VHIE that is made up of information about their health and the health care they have received from various doctors, hospitals, and other health care providers. Authorized providers can view information about the patients in their care who are participating with VITL. This shared health record can help keep providers on the same page, particularly when individuals are receiving treatment and services across several provider organizations.
What is the consent policy of the VHIE?
The VHIE operates according to an opt-out consent policy, which means that a Vermonter’s records in the VHIE are available to authorized users unless that individual has affirmatively elected not to have their health information shared in this way. Opting out through VITL prevents health care providers from accessing any part of the individual’s medical record in the VHIE; there is not an option to opt out of data sharing from or to a particular network participant.
Who will have access to the patient data shared with VITL?
The providers and professionals who have access to VITL data include:
- medical doctors
- nurse practitioners
- physician assistants
- nurses
- pharmacists
- care managers
- mental health providers
- home health care nurses
- dentists
- physical therapists
- emergency medical services providers (like EMTs and paramedics)
- staff at organizations that provide health care services
- other health care professionals covered under HIPAA
- public health professionals (providers and staff who work at the Vermont Department of Health)
- providers and staff at payers (insurers) and accountable care organizations, for a slightly narrower set of permitted uses, outlined in VITL’s Secondary Use Policy
How is security of patient information within the VHIE maintained?
VITL uses multiple strategies to ensure data in the Information Exchange is secure, including conformance to industry recognized security frameworks, like the NIST Cybersecurity Framework. Additionally, VITL actively monitors the use of the Information Exchange. All VITL staff are trained to identify and report security incidents. Unusual or malicious events are reviewed and addressed.
Under MDAAP, what patient information is shared with the VHIE?
Providers participating in MDAAP Track 1 and Track 3 will establish secure electronic connections to share Admission/Discharge/Transfer (ADT) messages and Continuity of Care Document (CCD) messages from their certified electronic health record (EHR) solutions with the Vermont Health Information Exchange (VHIE).
An ADT message often contains basic details about an encounter, such as patient demographics, insurance information, the date and time of the encounter, encounter type (e.g., new patient vs. established follow-up), location, provider, and diagnosis. In some outpatient settings, ADTs are configured to send a narrower set of information focused on patient demographics.
A CCD message contains patient demographic information and includes details about patient treatment, such as current diagnoses and past medical history, current medications, allergies, progress notes, and treatment plan information.
Psychotherapy notes should not be shared with VITL. Psychotherapy notes should be maintained separately from the rest of the medical record. They are not included in ADTs or CCDs.
Is it possible for an MDAAP-participating provider to withhold sharing certain information, such as progress notes or treatment plans, while allowing other interface message information to be shared with the VHIE?
No, providers connecting their EHR systems to the VHIE must share complete ADT and CCD messages. However, for mental health providers, it is important to point out that psychotherapy notes are not collected and shared by the VHIE.
What documentation events in the electronic health record (EHR) trigger the transmission of data to the VHIE?
In general, ADT messages are triggered when patients are registered (i.e., a new patient record is created in the EHR), when patient demographic information is updated, when appointments are scheduled, and when encounters are charted. CCD messages are generally triggered when a provider signs off to finalize some type of encounter note documentation such as a new patient evaluation or a progress note. What triggers an ADT message or sending of a CCD from a particular organization’s EHR instance is configurable by the practice or EHR, it is not determined by VITL.
In establishing ADT and CCD interfaces to the VHIE, does this only encompass sharing patient data from the time the interfaces are activated moving forward, or would this involve sharing all the historical data in the patient's chart?
ADTs may include past demographic and insurance information. CCDs typically contain significant historical data from the patient’s medical record.
Can a patient direct their mental health provider to not share their information with the VHIE?
Yes, an individual who does not want their mental health treatment records sent to VITL should express this desire to their mental health provider, who should document the request. While health care providers, EHR vendors, and health information exchanges must be careful to comply with the Information Blocking Rules in the 21st Century Cures Act, patients do have a right to request a restriction on how their data is used or shared. A provider may or may not be able or willing to fulfill this request and should communicate that to their patient. (See FAQs #11 and #12 below for more information on the Cures Act and exceptions to the Information Blocking Rules.)
What are the Information Blocking Rules, and how does this apply to sharing patient information with the VHIE?
In 2016, the 21st Century Cures Act (Cures Act) made sharing electronic health information the expected norm in health care, empowering patients with the right to access their health information electronically and have it shared electronically with other authorized providers of care. The Cures Act spells out reasonable and necessary activities that healthcare providers, health IT software vendors, and health information exchanges (collectively, the key actors) must undertake to avoid Information Blocking, which is defined as interference with the access, exchange, or use of electronic health information (EHI). You can read more about Information Blocking here: https://www.healthit.gov/topic/information-blocking.
Since the Cures Act was implemented, the key actors defined above must be careful not to implement any policies or practices that interfere with the access, exchange, or use of EHI, unless one of the defined exceptions to Information Blocking applies.
Is it ever permissible for a VITL-participating provider to hold back data from being sent to the VHIE?
The Cures Act contains 9 exceptions to sharing EHI, and when one or more exceptions are met, such non-sharing will not be considered an act of information blocking. For healthcare providers, the two most common exceptions are the Preventing Harm Exception and the Privacy Exception.
The Preventing Harm Exception allows a provider to withhold the sharing of EHI with a patient or other providers of care if in the provider’s professional opinion, such withholding is reasonable and necessary to prevent harm to the patient or to another person.
The Privacy Exception allows a provider to withhold the sharing of EHI with the VHIE in order to respect an individual’s documented request not to share information from a specified provider. (See FAQ #15 for guidance in the event a patient wishes to opt out of VHIE participation completely.)
Can I ask my EHR vendor to routinely block certain data elements from being included in the ADT and CCD messages sent to the VHIE?
Health IT software vendors are one of the key actors specifically named within the Information Blocking provisions of the Cures Act. As such, health IT vendors must ensure that they are not implementing any policies or practices that could be defined as interference with the access, exchange, or use of EHI. Therefore, health IT vendors are most likely to decline such a request and instead defer to the healthcare provider, who has an established treatment relationship with the patient, to determine if any Information Blocking exceptions exist on a case-by-case basis.
Are there any resources to help me have conversations with my patients about VHIE participation?
The best approach is to direct patients to https://vitl.net/for-vermonters/. This part of VITL’s website is designed to offer accessible information to individual Vermonters, including FAQs about data sharing and instructions on how individuals can formally opt out of having their record available through VITL.
How does a patient opt out of VHIE participation completely for all providers of care?
A patient wishing to opt out of having their information viewable to providers in the VHIE can visit https://vitl.net/for-vermonters/ for more information. Information and forms found at that site will enable individuals to do one of the following:
- Call the VITL patient hotline, 888-980-1243, to submit an opt-out request by phone
- Complete and submit the online opt-out form
- Download, print, and complete the paper version of the opt out form and mail it to VITL.
When an individual follows any of these avenues to opt out of VHIE participation, any patient data previously shared with the VHIE will be unavailable for future access in the VHIE (unless an individual later chooses to opt back in).
Can patient information be retracted if accidentally shared with the VHIE?
If patient data is sent to the VHIE in error, a provider can create a support ticket with VITL to request that the specific patient information be deleted or removed. Upon receipt of such a request, the specific information may be removed from the VHIE’s portal and reporting database if technically feasible. Instructions for how to submit a MyVITL support ticket can be found here: https://vitl.net/contact-us/.