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:
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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.
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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.
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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?
MDAAP incentives must be paid to eligible providers by March 31, 2025. Therefore, the last date to submit an MDAAP application is December 31, 2024, and the deadline for milestone attestation is February 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