Public Notices

Michigan Medicaid Electronic Health Record (EHR) Incentive Program

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This program allows incentive payments to eligible Medicaid providers to implement, upgrade, and demonstrate meaningful use of certified EHRs.
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  MICHIGAN DEPARTMENT OF COMMUNITY HEALTH NOTICE OF PROPOSED POLICY Public Act 280 of 1939, as amended, and consultation guidelines for Medicaid policyprovide an opportunity to review proposed changes in Medicaid policies and procedures.Please review the policy summary and the attached materials that describe the specificchanges being proposed. Let us know why you support the change or oppose the change.Submit your comments to the analyst by the due date specified. Your comments must bereceived by the due date to be considered for the final policy bulletin.Thank you for participating in the consultation process.Acting Director, Program Policy DivisionBureau of Medicaid Policy and Actuarial Services   ProjectNumber: 1054-EHR CommentsDue: January 19,2011 ProposedEffective Date: January 21,2011 Mail Comments to: MSA PolicyBureau of Medicaid Policy & Actuarial ServicesMedical Services AdministrationP.O. Box 30479Lansing, Michigan 48909-7979 Fax Number: (517) 335-5136 E-mail Address:  msadraftpolicy@michigan.gov  Policy Subject: Medicaid Electronic Health Record (EHR) Incentive Program Affected Programs: Medicaid Distribution: Physicians, Podiatrists, Dentists, Nurse Practitioners, Certified Nurse Midwives, PhysicianAssistants, Federally Qualified Health Centers (FQHC), Rural Health Clinics (RHC) Policy Summary: Establishes the Medicaid EHR Incentive Program for eligible professionals. Purpose: This program allows incentive payments to eligible Medicaid providers to implement, upgrade, anddemonstrate meaningful use of certified EHRs.  The public comment portion of this policy is being conducted concurrently with final. Public Comment Cover (11/03)    Bulletin  Michigan Department of Community Health   Bulletin Number: MSA 10-64 Distribution: Physicians, Podiatrists, Dentists, Nurse Practitioners, Certified Nurse Midwives,Physician Assistants, Federally Qualified Health Centers (FQHC), Rural Health Clinics(RHC) Issued: December 21, 2010 Subject: Medicaid Electronic Health Record (EHR) Incentive Program Effective: January 21, 2011 Programs Affected: MedicaidThe American Recovery and Reinvestment Act of 2009 (Recovery Act) provides the opportunity for stateMedicaid programs to improve the nation’s healthcare through health information technology (HIT) by authorizingincentives for certain eligible professionals (EP) for the meaningful use of EHRs.The HIT provisions of the Recovery Act are primarily found in Title XIII, Division A, Health InformationTechnology, and in Title IV, Division B, Medicare and Medicaid Health Information Technology. These titles takentogether are referred to as the Health Information Technology for Economic and Clinical Health (HITECH) Act.The Recovery Act established 100 percent Federal Financial Participation (FFP) to provide incentive payments toeligible Medicaid providers to purchase, implement, and operate, including support services and staff training, andcertified EHR technology.Medicaid professionals currently eligible for incentive payments include: ã Physicians ã Podiatrists ã Dentists ã Nurse Practitioners ã Certified Nurse Midwives ã Physician Assistants who are practicing in FQHCs or RHCs that are led by a physician assistant.These EPs must meet minimum Medicaid patient volume percentages (currently 20 percent for pediatricians and30 percent for other EPs) and cannot participate in the Medicare EHR incentive during the same year. EPs canreceive up to 85 percent of the net average allowable costs for certified EHR technology, including support andtraining, up to a maximum yearly level. Incentive payments are available for no more than a six year period.Incentive payments after the initial adoption, implementation, and upgrading of EHR technology, require theprovider to demonstrate meaningful use of the EHR technology. This is done through a means determined bythe State and approved by the Centers for Medicare and Medicaid Services (CMS). The State may also requireproviders to report clinical quality measures as a part of meaningful use. As required by CMS, the EHRtechnology must be compatible with State and Federal administrative management systems and certified with theCertification of Health IT Program under the Office of the National Coordinator for Health Information Technology(ONC).  MSA 10-64Page 2 of 3 To participate in the Medicaid EHR incentive program, EPs must register with the National Level Repository(NLR) at the federal level. To register with the NLR, all EPs must have a National Provider Identifier (NPI) and beenrolled in the CMS Provider Enrollment, Chain and Ownership System (PECOS). Most providers also need tohave an active user account in the National Plan and Provider Enumeration System (NPPES). CMS will usethese systems to register the EP for the program and verify the EP’s registration prior to notifying Michigan of theEP’s eligibility.EPs must also register as a provider in the Community Health Automated Medicaid Processing System(CHAMPS). EPs who are providing services through managed care entities must be individually registered as aMedicaid provider and are required to complete a similar process to verify the provider is in good-standing and iseligible to receive an EHR incentive. Information entered at the NLR may only be changed at the NLR level andmust match the information provided in CHAMPS. ã Currently Medicaid-Enrolled Provider- Once Medicaid receives a valid EP request from the NLR, theMedicaid staff will send a welcome letter to the EP with instructions for logging on to CHAMPS to registerfor the EHR incentive payment on-line. Once the EP submits the registration information, Medicaid staffwill start the review/validation process. ã Not Currently Medicaid-Enrolled Provider - Once Medicaid receives a valid EP request from the NLR, theMedicaid staff will send a welcome letter to the EP with instructions on enrolling in CHAMPS to registerfor the EHR incentive payment on-line. Note that this enrollment is for EHR incentive purposes only.To access the CHAMPS system for enrollment, the EP must follow the directions on the website atwww.michigan.gov/medicaidproviders, scroll down the middle of the page to Hot Topics  , and click on the CHAMPS  link. Once on the CHAMPS page, scroll down to Accessing the CHAMPS system  for step bystep instructions. Providers can also call 1-800-292-2550, option 2 for questions regarding CHAMPSenrollment. Once approved, the EP will receive a letter with instructions on completing the EHR portionof the enrollment.All participating EPs, will have to re-register every year. This will ensure the EPs report on meaningful use,re-attest to eligible patient volume information, and other administrative information. They will also be required tocomplete an annual survey that will address general EHR issues and concerns.Because many of the implementation details of this program are being developed and modified by CMS, furtherdetails can be found on websites specific to the Incentive Program.Updated and detailed information on the Medicaid EHR Incentive Program will be maintained and isavailable athttp://michiganhealthit.org.For a complete list of meaningful use criteria, visithttp://michiganhealthit.org/meaningful_useto reviewthe final US Department of Health and Human Services rule.For a list of Office of the National Coordinator (ONC) Certified EHR Technology, visithttp://healthit.hhs.gov.In addition to creating Medicaid and Medicare financial incentives, to speed the adoption of EHRs,Congress has also authorized Regional Extension Centers (REC) to provide on-site technical support tohelp providers adopt and achieve meaningful use with an EHR. Contact Michigan’s REC, M-CEITA, at1-888-MICH-EHR orwww.mceita.org.  MSA 10-64Page 3 of 3 Public Comment The public comment portion of the policy promulgation process is being conducted concurrently with theimplementation of the change noted in this bulletin. Any interested party wishing to comment on the change maydo so by submitting comments in writing to:Attn: MSA PolicyMDCH/MSAPO Box 30479Lansing, Michigan 48909-7979OrE-mail:msadraftpolicy@michigan.gov If responding by e-mail, please include “EHR EP Policy” in the subject line.Comments received will be considered for revisions to the change implemented by this bulletin. Manual Maintenance  Retain this bulletin until applicable information has been incorporated into the Michigan Medicaid ProviderManual. Questions Any questions regarding this bulletin should be directed to Provider Inquiry, Department of Community Health,P.O. Box 30731, Lansing, Michigan 48909-8231, or e-mail atProviderSupport@michigan.gov. When you submitan e-mail, be sure to include your name, affiliation, and phone number so you may be contacted if necessary.Providers may phone toll-free 1-800-292-2550. Approved Stephen Fitton, DirectorMedical Services Administration
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