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NC Medicaid Electronic Health Record Incentive Program FAQ

Frequently Asked Questions

Some of the FAQs found below have been adapted from the CMS FAQ Page. For more information, please see the CMS Promoting Interoperability Program website.

General Program Information

General Program Information

Who do I contact if I have questions?

Email our help desk anytime! NCMedicaid.HIT@dhhs.nc.gov  

I just learned about the NC Medicaid EHR Incentive Program and would like to attest. Am I eligible?

The NC Medicaid EHR Incentive Program is no longer accepting new applicants. Providers must have attested successfully at least once before April 30, 2017, to be able to participate in the NC Medicaid EHR Incentive Program in program years 2017-2021.

If you have just heard about the NC Medicaid EHR Incentive Program and are unsure if you, or the providers in your practice, are eligible to attest for Program Year 2019, please watch the Basic Eligibility Requirements webinar (Run Time: 5:03).  This webinar provides an overview of the most basic eligiblity requirements.

What is the latest date an EP can submit a Program Year 2019 attestation?

North Carolina has adopted an attestation tail period of 120 days to allow for attestation beyond the end of the payment year. That means EPs will have until April 30, 2020 to attest for Program Year 2019; however, if submitted after February 28, 2020, review by program staff prior to close of NC-MIPS is not guaranteed.

If I successfully attested in Program Year 2017 and skipped Program Year 2018, do I lose that payment year?

Participation years do not need to be consecutive. For example, if an EP successfully attest in Program Year 2017, but didn’t attest to MU in Program Year 2018, they may still attest to MU in Program Year 2019.

As long as the EP participates for six years before Program Year 2021 closes, they may earn the full incentive payment of $63,750.

Providers must have attested successfully at least once before April 30, 2017 to be able to participate in the NC Medicaid EHR Incentive Program in Program Years 2017-2021.

May I still submit a first year AIU attestation?

No. The last year an EP could attest to AIU was Program Year 2016. Providers must have attested successfully at least once before April 30, 2017 to be able to participate in the NC Medicaid EHR Incentive Program in Program Years 2017-2021.

The NC Medicaid EHR Incentive Program is no longer accepting first year or AIU attestations.

I attested with Medicare's EHR Incentive Program before but switched to the NC Medicaid EHR Incentive Program (before Program Year 2015). Do I attest for another first-year incentive payment since this is my first year attesting with Medicaid?

No. If an EP attests with ANY EHR Incentive Program (Medicare or another state Medicaid EHR Incentive Program), that counts as a year of participation in the EHR Incentive Program. So, if the EP attested with Medicare during their first participation year, when attesting with Medicaid, the EP would be attesting for a second-year payment (90-day MU) and it will be as if they attested with Medicaid the entire time.

For more information, please see CMS’ Promoting Interoperability Program website.

Once I receive my first payment, do I need to attest every consecutive year?

Participation in the program is encouraged but is not required. You may apply for one incentive payment each year, for up to six years, through the end of the program in 2021. You do not have to attest each year to remain eligible to participate.

I received a notice on September 10, 2018 from Greenway Health regarding the time frame used to calculate View, Download, Transmit (VDT) and Patient-Specific within Prime Suite that may have led to reporting a higher result than achieved. What do I need to do?

You need to:

  1. Keep a copy of this email from Greenway and any other related communication from Greenway, for six years.
  2. Take screenshots of the applicable measures for your reported performance period prior to Oct. 5, 2018, for your records and keep for six years.

If selected for audit for Program Year 2017, you may need to submit, in addition to the standard documentation requested on the records request letter, communication from Greenway to the provider who attested (or to her/his practice), screenshots taken prior to Oct. 5, 2018 of the applicable measures for your Program Year 2017 reporting period, and revised performance measures retrieved from your EHR after Greenway’s fix.

For questions regarding audit, please email NCMedicaid.HITInvestigator@dhhs.nc.gov.

Eligibility

Eligibility

Am I eligible to participate in the NC Medicaid EHR Incentive Program?

Providers who successfully attested at least once by Apr, 30, 2017 and have not received all six incentive payments may be eligible to apply for Program Year 2019. Click here for a list of all providers who have participated at least once but less than six years in the NC Medicaid EHR Incentive Program. If a provider is not on this list and the practice or provider is unsure of past participation, please email the provider's NPI to NCMedicaid.HIT@dhhs.nc.gov and we will check to see if the provider is eligible to attest in Program Year 2019. Please note, providers who are listed as a New Meaningful User on this list have only attested to AIU and therefore may attest now on NC-MIPS using a 90-day MU and CQM reporting period.

Each year of attestation, to be eligible to apply for an NC Medicaid EHR incentive payment, a provider must:

1. Have a certified EHR technology.

  • In Program Year 2019, all EPs must have a 2015 Edition of certified EHR technology.
  • Please see ONC’s Certified Health IT Product List (CHPL) to see if it meets certification criteria. Please work with your  EHR vendor if you are unsure of what version of EHR you have in your practice. 
  • Here is a two-minute video that shows step-by-step how to pull the CEHRT ID number from CHPL and update that number on CMS' R&A System: An Overview of CMS EHR Certification ID Numbers (Run time: 2:07).

2. Meet the required Medicaid Patient Volume (PV) threshold.

  • All EPs must have at least 30% Medicaid-enrolled encounters in a consecutive 90-day period.
  • Pediatricians may qualify for a reduced payment if they have 20% Medicaid-enrolled encounters. 
  • Watch our six-minute webinar to explain the basics of patient volume: Patient Volume Basics for the NC Medicaid EHR Incentive Program (Run time: 6:04).

3. Meet MU and CQM requirements. In Program Year 2019, EPs will be attesting to Stage 3 MU and 2019 CQMs.

4. Have participated successfully at least once in program years 2011-2016. NOTE: All EPs on the list of past participants have met this requirement.

  • EPs must have successfully attested at least once, to AIU or MU, by Program Year 2016 to be able to participate in the NC Medicaid EHR Incentive Program in program years 2017-2021. A denied attestation does not count as a successful attestation. 
  • If you meet all the requirements listed above, but are unsure if you successfully attested prior to April 30, 2017, please send an email with your NPI to NCMedicaid.HIT@dhhs.nc.gov and we will look it up for you.

5. Be an eligible provider type. NOTE: All EPs on the list of past participants have met this requirement. These provider types include:

  • Physicians;
  • Nurse practitioners;
  • Certified nurse midwives;
  • Dentists; and,
  • PAs who furnish services in an FQHC/RHC that is led by a PA.

We have a short video EPs can watch to help determine eligibility (Run time: 4:30). And once eligibility is determined, we have another short video that highlights how to get started with the attestation process (Run time: 4:22). 

Email NCMedicaid.HIT@dhhs.nc.gov with questions or for assistance with a Program Year 2019 attestation.

If you have just heard about the NC Medicaid EHR Incentive Program and are unsure if you are eligible to attest for Program Year 2019, please watch the Basic Eligibility Requirements webinar (Run Time: 5:03).  This webinar provides the most basic eligibility requirements, so if you're unsure if you may be eligible to attest, watch this webinar.

Under the NC Medicaid EHR Incentive Program, are there a minimum number of hours per week that an EP must practice in order to qualify for an incentive payment? Could a part-time EP qualify for an incentive payment if the EP meets all other eligibility requirements?

There are no restrictions on employment type (e.g., contractual, permanent, or temporary - regardless of number of hours worked). So, a part-time EP who meets all other eligibility requirements could qualify for payments under the NC Medicaid EHR Incentive Program.

How does NC define 'hospital-based' for eligible professionals?

A hospital-based eligible professional (EP) is defined as an EP who furnishes 90 percent or more of their covered professional services in either the inpatient (Place of Service 21) or emergency department (Place of Service 23) of a hospital. Covered professional services are physician fee schedule (PFS) services paid under Section 1848 of the Social Security Act. To determine whether an EP is hospital-based, EPs may use encounter data from either the fiscal year prior to program year or calendar year prior to program year.

Will the resident physicians that are employed at university hospitals be eligible to participate in the NC Medicaid EHR Incentive Program?

Physicians who furnish substantially all (defined as 90 percent or more) of their covered professional services in either an inpatient or emergency department of a hospital are considered to be hospital-based.

A hospital-based EP that can demonstrate to CMS that they funded the acquisition, implementation and maintenance of certified EHR technology (CEHRT), including supporting hardware and interfaces needed for meaningful use without reimbursement from an EH or CAH, and uses such CEHRT in the inpatient or emergency department of a hospital (instead of the hospital’s CEHRT), may be determined by CMS to be a non-hospital based EP and may be eligible to participate in the Medicaid EHR Incentive Program.

What are the requirements for dentists participating in the NC Medicaid EHR Incentive Program?

Dentists must meet the same eligibility requirements as other eligible professionals (EP) to qualify for payments under the Medicaid EHR Incentive Program. EPs will have to evaluate whether they individually meet the Meaningful Use (MU) measures and if they qualify to meet the exclusion criteria for each applicable objective as there is no blanket exclusion for any EP.

I am an NP who has a pediatric taxonomy on NCTracks. May I qualify at the reduced Medicaid PV threshold of 20 percent?

No. Medicaid recognizes an Eligible Professional as being a pediatrician only if they are a Doctor of Medicine (MD) or a Doctor of Osteopathic Medicine (DO) and meet one of the following requirements below:

  • Enrolled with NC Medicaid as a pediatrics specialty; or,
  • Board certified by a national certification board in a Pediatrics, Adolescent or Child medical specialty area.

I am an FQHC/RHC. Do I have to attest to practicing predominantly?

It is not required for an FQHC/RHC provider to attest to practicing predominantly, unless they wish to use non-Medicaid needy individual encounters to count toward their 30 percent Medicaid patient volume threshold. If the EP is not using non-Medicaid needy individual encounters, they do not have to attest to practicing predominantly.

NOTE: For more complete information about eligibility requirements, please refer to CMS’ Promoting Interoperability Program website.

How does CMS define an FQHC and an RHC for the purposes of the NC Medicaid EHR Incentive Program?

The Social Security Act at section 1905(l)(2) defines an FQHC as an entity which:
"(i) is receiving a grant under section 330 of the Public Health Service Act, or (ii)(I) is receiving funding from such a grant under a contract with the recipient of such a grant and (II) meets the requirements to receive a grant under section 330 of the Public Health Service Act, (iii) based on the recommendation of the Health Resources and Services Administration within the Public Health Service, and is determined by the Secretary to meet the requirements for receiving such a grant including requirements of the Secretary that an entity may not be owned, controlled, or operated by another entity; or (iv) was treated by the Secretary, for purposes of Part B of title XVIII, as a comprehensive Federally-funded health center as of January 1, 1990, and includes an outpatient health program or facility operated by a tribe or tribal organization under the Indian Self-Determination Act or by an urban Indian organization receiving funds under Title V of the Indian Health Care Improvement Act for the provision of primary health services."

RHCs are defined as clinics that are certified under section 1861(aa)(2) of the Social Security Act to provide care in underserved areas, and therefore, to receive cost-based Medicaid reimbursements.

In considering these definitions, it should be noted that programs meeting the FQHC requirements commonly include the following (but must be certified and meet all requirements stated above): Community Health Centers, Migrant Health Centers, Healthcare for the Homeless Programs, Public Housing Primary Care Programs, FQHC Look-Alike's, and Tribal Health Centers.

If a Federally Qualified Health Center (FQHC) or Rural Health Center (RHC) is led by a physician assistant (PA), are all PAs at that FQHC or RHC eligible for the program?

Yes, all PAs who furnish services in an FQHC or RHC that is PA-led are eligible professionals (EPs) under the NC Medicaid EHR Incentive Program, so long as the PAs meet all other Program eligibility requirements (30 percent Medicaid/needy individual PV, not hospital-based, etc.). 

Like other EPs at an FQHC or RHC, upon receipt of attestation, eligible PAs may be asked to provide additional documentation of any services provide either at no cost or at reduced cost based on a sliding scale determined by the individuals’ ability to pay.

What documentation is needed to demonstrate eligibility for being a PA-led facility?

The Final Rule states, a PA would be leading an FQHC or RHC under any of the following circumstances:

  1. The PA is the primary provider in a clinic (for example, when there is a part-time physician and full-time PA, we would consider the PA as the primary provider);
  2. The PA is a clinical or medical director at a clinical site of practice; or,
  3. The PA is an owner of an RHC.

For eligibility, PA-led facilities should submit documentation on group letterhead speaking to one of the three requirements mentioned above.

May I participate in Medicare’s MIPS program and the NC Medicaid EHR Incentive Program at the same time?

Yes. The Merit-based Incentive Payment System (MIPS) does not replace the Medicaid EHR Incentive Program. If a provider plans to participate in the Medicaid EHR Incentive Program through their state and they are also a Medicare Part B clinician who is eligible for MIPS, they will also need to participate in the MIPS program to avoid a negative MIPS payment adjustment. For more information, please click here and go to page 64.

I participated in Medicaid's EHR Incentive Program but switched to Medicare's EHR Incentive Program prior to Program Year 2015. May I now switch back and participate in the Medicaid EHR Incentive Program?

No. EPs were only allowed to switch between the Medicare and Medicaid EHR Incentive programs one time and it had to be done by Program Year 2014. If you are unsure of your past participation, please email NCMedicaid.HIT@dhhs.nc.gov.

Are hospitals in NC still able to participate in the NC Medicaid EHR Incentive Program in Program Year 2019?

No. After Program Year 2016, EHs must have participated in consecutive years to continue participating in the EHR Incentive Program in program years 2017-2021. Please see the excerpt below from the Stage 1 Final Rule (pg. 44319) which states:

 “For hospitals, however, starting with fiscal year 2017 payments must be consecutive. This rule is required by section 1903(t)(5)(D) of the Act, which states that after 2016, no Medicaid incentive payment may be made to an eligible hospital unless ‘‘the provider has been provided payment for the previous year.’’ As a result, Medicaid eligible hospitals must receive an incentive in fiscal year 2016 to receive an incentive in fiscal year 2017 and later years. Starting in fiscal year 2016, incentive payments must be made every year in order to continue participation in the program.”

There were no hospitals in NC who submitted a year two attestation in Program Year 2017. As a result, the NC Medicaid EHR Incentive Program is no longer accepting hospital attestations. Please see CMS’ Promoting Interoperability Program website for more information on attestation opportunities within the Medicare PI Program.

Registration and Attestation

Registration and Attestation

Do providers register only once for the NC Medicaid EHR Incentive Program or do they register every year?

Providers are only required to register once for the NC Medicaid EHR Incentive Program. However, they must successfully demonstrate that they have met meaningful use (MU) of their certified EHR technology each year they attest in order to receive an incentive payment for that year.

Additionally, providers seeking the Medicaid incentive must annually re-attest to other program requirements, such as meeting the required patient volume thresholds.

For large practices, will there be a method to registering all EPs at one time for the NC Medicaid EHR Incentive Program? Can EPs allow another person to register/attest for them?

Please note, the individual provider is liable for the information provided on the attestation.

The North Carolina Medicaid EHR Incentive Payment System (NC-MIPS) system will not allow one person to use one NCID to attest for multiple EPs.

In April 2011, CMS implemented functionality that allows an EP to designate a third party to register on her or his behalf. To do so, users working on behalf of an EP must have an Identity and Access Management System (I&A) web user account (User ID/Password) and be associated to the EP's NPI.

I need an NCID (North Carolina Identity Management Identifier) to register for the program. What kind of account do I need?

NCID is the standard identity management and access service provided to state, local, business, and individual users, and is required when registering for the NC Medicaid EHR Incentive Program. NCID accommodates many types of user communities, including:

  • Business users request access to the State of North Carolina on the behalf of a business.
  • Individuals request access to conduct online transactions with the state of North Carolina. These users may or may not be citizens of the state.
  • State government employees are employed or contracted to work for an agency within the state of North Carolina government.
  • Local government employees are employed or contracted to work for a North Carolina county or municipality.
  • Administrators are state and local government employees who can administer user accounts within the same organization, division(s) and/or section(s) for which she or he has administrative rights (i.e. Delegated Administrators, Application Administrators, Service Desk).
  • Providers who are not state or local government should register as Business users. However, in coordinating efforts with Medicaid eligibility and enrollment, including the re-credentialing process, those who are employed or contracted to work for a state agency or locality must register as state or local government employees, respectively. Any fees associated with obtaining an NCID for the purposes of attesting for an incentive payment cannot be waived by NC Medicaid.

For any questions or concerns regarding your NCID account, please visit ncid.nc.gov or contact the NCID help desk at (919) 754-6000.

I just recently moved to North Carolina but received a Medicaid incentive payment from the state where I practiced last year. How do I attest this year with the NC Medicaid EHR Incentive Program?

Providers need to visit the CMS Registration & Attestation (R&A) System, update their state to "NC" and ensure their contact information is updated. Then email NCMedicaid.HIT@dhhs.nc.gov with your last name and NPI to be added to our attestation portal, the NC Mediciad EHR Incentive Payment System (NC-MIPS).

I have a new provider in our practice this year and they don't know if they've received an incentive payment. Where can I go to see if they have participated in, and received money for, the Medicare or Medicaid EHR Incentive Program?

This information can be found on CMS' Registration & Attestation System under the attesting provider's registration information.

Alternatively, for those practices unsure if a new provider can participate in the NC Medicaid EHR Incentive Program in Program Year 2019, please email the provider’s last name and NPI to NCMedicaid.HIT@dhhs.nc.gov and program staff will determine if the provider previously attested with another practice.

Where can I find help with the attestation process?

Detailed, step-by-step attestation assistance can be found in the Stage 3 MU Attestation Guide. This is posted on the NC-MIPS website to help providers with the attestation process.

You can also email your questions to the NC-MIPS Help Desk at NCMedicaid.HIT@dhhs.nc.gov.

What are the next steps after a provider emails the signed attestation?

Attestations are validated in the order they were received and go through a series of verification checks. Once the validation process is completed and if there are no attestation discrepancies, the EP will be made eligible for payment and all payments will be posted on the program website under the "Path to Payment" tab once the electronic file transfer (EFT) is processed. If there are attestation discrepancies and the Program Year 2019 attestation has been submitted by Feb. 28, 2020, we will conduct outreach.

Providers may see the status of their attestation on the NC-MIPS Status page.

I am a proxy attesting on behalf of a provider. May I sign the attestation, or does it need to be signed by the attesting EP

The attesting EP must physically sign and date the printed attestation her/himself. A third party, such as a practice manager, may not sign the printed attestation on behalf of the EP. Electronic signatures and stamps are not accepted.

Do I have to submit my attestation via email?

Yes. To meet MU, the signed attestation summary, signed MU Summary page, signed CQM Summary page, and the CQM report pulled directly from the EP's EHR demonstrating s/he met the CQMs for which s/he attested, must be submitted electronically (via email) to NCMedicaid.HIT@dhhs.nc.gov.

Do I have to attest to the Prevention of Information Blocking Attestation to participate in the NC Medicaid EHR Incentive Program in Program Year 2019?

Yes, all EPs participating in the EHR Incentive Program are required to show that they have not knowingly and willfully limited or restricted the computability or interoperability of their CEHRT. EPs will do this by attesting to three statements about how they implement and use CEHRT. These three statements are referred to as the "Prevention of Information Blocking Attestation." To see the Prevention of Information Blocking Attestation Fact Sheet from CMS, please see the following link: https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/EHR_InformationBlockingFact-Sheet20171106.pdf

EPs attesting to the NC Medicaid EHR Incentive Program will see these three statements on the attestation summary PDF that is printed from NC-MIPS. These three statements are (With my signature below, I attest that I):

Patient Volume (PV) for Eligible Professionals (EPs)

Patient Volume (PV) for Eligible Professionals (EPs)

How is PV calculated?

EPs need 30 percent Medicaid PV (20 percent for Pediatricians - for a reduced payment) to be eligible for the incentive program.

To calculate the Medicaid PV percentage, use the following formula:

Numerator:
Medicaid PV = All billable services rendered on any one day to a Medicaid-enrolled individual, regardless of payment liability (this includes zero-pay claims) in a consecutive 90-day period. The numerator should include all encounters where Medicaid paid at least part, even if Medicaid was not the primary payer.

Denominator:
Total PV = All encounters, regardless of the payment method in the same 90-day period.

EPs may choose as their reporting period any consecutive 90-day period within the calendar year prior to the program year for which they’re attesting or from the 12 months prior to the date of the attestation.

How do I calculate my PV numerator?

In general, providers should follow the general guidelines below:
Determine the total number of encounters during the PV reporting period.

From the total number of encounters, determine which patients are Medicaid-enrolled (The EP must have a mechanism for determining who is Medicaid-enrolled, this will be very important if they are selected for audit). Include all encounters where Medicaid paid at least part, even if Medicaid was not the primary payer.

From the list of Medicaid-enrolled encounters, determine which encounters are considered "billable services."

What is a billable service?

Examples of billable services include:

  • Encounters denied for payment by Medicaid or that would be denied if billed due to exceeding the allowable limitation for the service/procedure;
  • Encounters denied for payment by Medicaid or that would be denied if billed because of lack of following correct procedures as set forth in the state’s Medicaid clinical coverage policy such as not obtaining prior approval prior to performing the procedure;
  • Encounters denied for payment due to not billing in a timely manner;
  • Encounters paid by another payer which exceed the potential Medicaid payment; and,
  • Encounters that are not covered by Medicaid such as some behavioral health services, HIV/AIDS treatment, or other services not billed to Medicaid for privacy reasons, oral health services, immunizations, but where the provider has a mechanism to verify Medicaid eligibility.

Further, the Final Rule defines billable as follows:

  • Concurrent care or transfer of care visits;
  • Consultant visits; or,
  • Prolonged physician service without direct, face-to-face patient contact (for example, tele-health).
  • A consultant visit occurs when a provider is asked to render an expert opinion/service for a specific condition or problem by a referring provider. The visit does not have to be individually billable in instances where multiple visits occur under one global fee.

Billable services do not include:

  • Encounters denied for payment by Medicaid or that would be denied if billed because of absence of medical necessity under the state’s Medicaid clinical coverage policy; and,
  • Encounters denied for payment by Medicaid because the patient was not enrolled in Medicaid at the time the service was rendered.

When EPs work at more than one clinical site of practice, are they required to use data from all sites of practice to support their PV thresholds for the NC Medicaid EHR Incentive Program?

EPs may choose one or more clinical sites of practice to calculate their PV. This calculation does not need to be across all of an EP’s sites of practice. However, at least one of the locations where the EP is adopting or meaningfully using certified EHR technology must be included in the PV.

What NC Medicaid PV threshold must pediatricians meet to be eligible for an EHR incentive payment?

NC Medicaid recognizes an eligible professional as being a pediatrician if they are a Doctor of Medicine (MD) or a Doctor of Osteopathic Medicine (DO) and meet one of the following requirements below:

  • Enrolled with NC Medicaid as a pediatrics specialty; or,
  • Board certified by a national certification board in a Pediatrics, Adolescent, or Child medical specialty area.

A pediatrician that demonstrates at least 30 percent Medicaid PV, along with all other program requirements, is eligible to receive the full incentive payment amount. A pediatrician that demonstrates at least 20 percent Medicaid PV, along with all other program requirements, may participate for a reduced payment valued at two-thirds the full incentive amount.

Are pediatric Nurse Practitioners eligible for the reduced 20 percent Medicaid PV threshold?

No. Pediatricians are the only group of EPs that qualify for the reduced 20 percent PV threshold. Other EPs, including nurse practitioners, must meet the regular requirement of 30 percent Medicaid PV.

North Carolina defines a pediatrician as a Doctor of Medicine (MD) or a Doctor of Osteopathic Medicine (DO) that is enrolled with NC Medicaid as a pediatrics specialty or is board certified by a national certification board in a Pediatrics, Adolescent or Child medical specialty area.

Do FQHCs or RHCs must meet the 30 percent minimum Medicaid PV threshold to receive an NC Medicaid EHR Incentive Payment?

*Note: All incentive payments are tied to individual EPs. Therefore, as entities, FQHCs and RHCs are not eligible to attest for and receive payment under the program. However, EPs who work at an FQHC or RHC may be eligible to participate and can use needy individuals to meet the PV threshold.

EPs who work at an FQHC or RHC and meet the eligibility requirements may participate in the NC Medicaid EHR Incentive Program if: 1) They meet Medicaid PV thresholds individually, or if the FQHC/RHC meets PV requirements as a group; or 2) They practice predominantly in an FQHC or RHC and have 30 pecent needy individual PV. In addition to Medicaid-enrolled encounters, needy individuals include NC Health Choice patients as well as patient encounters where services were provided either at no cost or at reduced cost based on a sliding scale determined by the patient’s ability to pay.

EPs may be eligible using individual or as a group PV methodology. For more information regarding group and individual methodology when calculating PV, please visit the PV tab of our Program website.

When calculating PV, can EPs that practice primarily in a clinic, but also see patients in hospitals, count their inpatient and outpatient hospital visits as encounters?

Yes. EPs may (but are not required to) count their hospital-based encounters (inpatient and outpatient) when calculating their PV. This rule must be applied consistently to both the numerator and the denominator.

A hospital-based EP that can demonstrate to CMS that they funded the acquisition, implementation and maintenance of certified EHR technology (CEHRT), including supporting hardware and interfaces needed for meaningful use without reimbursement from an eligible hospital or CAH, and uses such CEHRT in the inpatient or emergency department of a hospital (instead of the hospital’s CEHRT, may be determined by CMS to be a non-hospital based EP and may be eligible to participate in the Medicaid EHR Incentive Program.

For the NC Medicaid EHR Incentive Program, how should I determine Medicaid PV for procedures that are billed globally, such as obstetrician (OB) visits or some surgeries?

Global billing situations such as OB/GYN visits should be counted on the date of service, not the date of billing. Each individual date of service is considered to be one encounter.

When counting encounters in a clinic or medical group (or medical home model) for purposes of the NC Medicaid EHR Incentive Program, am I able to include the encounters of ancillary providers such as pharmacists, educators, etc. when determining if I meet the Medicaid PV threshold?

CMS regulations did not address whether these non-EP encounters could be considered in the estimate of PV for the clinic. However, they believe a state would have the discretion to include such non-EP encounters in its estimates. NC allows these encounters to be included in the PV calculation.

If these non-EP encounters are included in the numerator, they must be included in the denominator as well. States also must ensure that their methodology adheres to the conditions in 42 CFR 495.306(h), and specifically t 495.306(h)(4), which says: “(4) The clinic or group practice uses the entire practice or clinic’s patient volume and does not limit patient volume in any way.”

For more information, see the final rule.

If an EP wants to leverage a clinic or group practice's PV as a proxy for the individual EP, how should a clinic or group practice account for EPs practicing part-time and/or applying for the NC Medicaid EHR Incentive Program through a different location (e.g., where an EP is practicing both inside and outside the clinic/group practice, such as part-time in two clinics)?

EPs may use a clinic or group practice’s PV as a proxy for their own under five conditions:

  1. The attesting EP had at least one encounter with a Medicaid-enrolled patient during the program year.
  2. The clinic or group practice’s PV is appropriate as a PV methodology calculation for the attesting EP (for example, if an EP only sees Medicare, commercial, or self-pay patients, this is not an appropriate calculation); 
  3. There is an auditable data source to support the EP’s PV determination;
  4. The EP has a current affiliation with the clinic whose PV s/he is using to attest; and,
  5. So long as the practice and EPs decide to use one methodology for a 90-day reporting period (in other words, clinics could not have some of the EPs using their individual PV for patients seen at the clinic, while others use the clinic-level data during the same 90-day reporting period). The clinic or group must use the entire group’s PV and not limit it in any way. EPs may attest to PV under the individual calculation or the group/clinic proxy in any participation year. Furthermore, if the EP works in both the clinic and outside the clinic (or with and outside a group practice), then the clinic/group level determination includes only those encounters associated with the clinic/group.

Are there any stipulations around using a group’s PV?

Yes. EPs may use a clinic or practice’s group PV as a proxy for their own under five conditions:

  1. The attesting EP had at least one encounter with a Medicaid-enrolled patient during the program year.
  2. The clinic or group practice’s PV is appropriate as a PV methodology calculation for the attesting EP (for example, if an EP only sees Medicare, commercial, or self-pay patients, this is not an appropriate calculation); 
  3. There is an auditable data source to support the clinic’s PV determination;
  4. The EP has a current affiliation with the groups' PV they are using to attest; and,
  5. So long as the practice and EPs decide to use one methodology for a 90-day reporting period (in other words, clinics could not have some of the EPs using their individual PV for patients seen at the clinic, while others use the clinic-level data during the same 90-day reporting period). The clinic or practice must use the entire practice’s PV and not limit it in any way. EPs may attest to PV under the individual calculation or the group/clinic proxy in any participation year. Furthermore, if the EP works in both the clinic and outside the clinic (or with and outside a group practice), then the clinic/practice level determination includes only those encounters associated with the clinic/practice.

Are FQHC look-alike's eligible for the "practicing predominantly in an FQHC" requirement of the NC Medicaid EHR Incentive Program, allowing them to use non-Medicaid needy individual encounters toward the Medicaid PV threshold?

EPs practicing at an FQHC look-alike are eligible for the “practicing predominantly” requirement of the NC Medicaid EHR Incentive Program so long as they meet all the requirements EPs of an FQHC are subject to as defined by CMS. Eligibility for “practicing predominantly in an FQHC” allows the EP to use needy individual encounters toward the patient volume requirement.

For more information, please visit CMS' FAQ website.

Is it permissible to count services provided to "presumptive eligible" recipients in the PV calculation?

Yes. EPs may include patient encounters with presumptive eligible recipients in the patient volume calculation. Since presumptive eligibility is generally short-term, make sure the patient still had presumptive eligibility status when the service was provided in order to count it toward your Medicaid patient volume.

If the providers in my practice attested using individual methodology to calculate patient volume last year but would like to attest using group methodology to calculate patient volume this year, is it ok for them to switch?

Yes. Providers may select their patient volume methodology each year of participation in the NC Medicaid EHR Incentive Program and it can alter year to year. If you can - go group! Group methodology allows you to calculate one percentage for all affiliated attesting providers.

How does the NC Medicaid EHR Incentive Program define an 'encounter'?

For EPs, a Medicaid-paid encounter is defined as services rendered on any one day to an individual where Medicaid or a Medicaid demonstration project under Section 1115 of the Social Security Act paid for part or all of the service as stated in the Final Rule.

CMS further defines a patient encounter as any encounter where a medical treatment is provided and/or evaluation and management services are provided.

It is important to note that EPs must count actual encounters, defined as a unique patient on a unique day, from their own auditable data source, defined as an electronic or manual system that an external entity can use to replicate the data from the original data source to support their attested information.

Exclude anything from your numerator and denominator that’s not an encounter, such as management fees like system-generated management fees for Carolina Access -CCNC (ICN region code 80 on Medicaid claims). These are paid Medicaid claims but there is no encounter tied directly to this.

Health Choice encounters may not be included in the numerator of the Medicaid patient volume calculation, except in the case of EPs who practice predominantly at a Federally Qualified Health Center (FQHC) or Rural Health Clinic (RHC). FQHCs and RHCs can include these as non-Medicaid needy in their numerator.

Zero-pay Medicaid encounters are encounters with Medicaid patients that were billable services but where Medicaid did not pay.

Examples of billable services include:

  • Encounters denied for payment by Medicaid or that would be denied if billed due to exceeding the allowable limitation for the service/procedure;
  • Encounters denied for payment by Medicaid or that would be denied if billed because of lack of following correct procedures as set forth in the state’s Medicaid clinical coverage policy such as not obtaining prior approval prior to performing the procedure;
  • Encounters denied for payment due to not billing in a timely manner;
  • Encounters paid by another payer which exceed the potential Medicaid payment; and,
  • Encounters that are not covered by Medicaid such as some behavioral health services, HIV/AIDS treatment, or other services not billed to Medicaid for privacy reasons, oral health services, immunizations, but where the provider has a mechanism to verify Medicaid eligibility.

Further, the Final Rule defines billable as follows:

  • Concurrent care or transfer of care visits;
  • Consultant visits; or,
  • Prolonged physician service without direct, face-to-face patient contact (for example, tele-health).

A consultant visit occurs when a provider is asked to render an expert opinion/service for a specific condition or problem by a referring provider. The visit does not have to be individually billable in instances where multiple visits occur under one global fee.

Billable services do not include:

  • Encounters denied for payment by Medicaid or that would be denied if billed because of absence of medical necessity under the state’s Medicaid clinical coverage policy; and,
  • Encounters denied for payment by Medicaid because the patient was not enrolled in Medicaid at the time the service was rendered.

To qualify as an encounter, an EP must "see a patient." How does an EP determine whether a patient has been "seen by the EP" in cases where the service rendered does not result in an actual interaction between the patient and the EP? Do patients seen via telemedicine qualify as an encounter?

A Medicaid encounter is defined as services rendered to an individual on a unique day where the individual was enrolled in a Medicaid program (or a Medicaid demonstration project approved under Section 1115 of the Social Security Act) at the time the billable service was provided. In other words, an encounter is a unique patient on a unique day with a unique provider.

All cases where the EP has an actual physical encounter with a patient and renders a service to the patient should be included in the denominator as “seen by the EP.” 

All cases where patients are seen via telemedicine qualify as encounters. All telemedicine encounters must be included in the denominator, and those encounters where Medicaid paid part, or all of the services, should be included in the numerator.

In cases where the EP and the patient do not have an actual physical or telemedicine encounter, but the EP renders a minimal consultative service for the patient (like reading an EKG), the EP may choose whether to include the patient in the denominator as “seen by an EP” provided the choice is consistent for the entire EHR reporting period and for all the relevant meaningful use (MU) measures.

EPs who never have a physical or telemedicine interaction with patients must adopt a policy that classifies at least some of the services they render for patients as “seen by the EP.” This methodology must be consistent across the entire Promoting Interoperability (PI) reporting period (formerly MU reporting period) and across MU measures that involve patients “seen by the EP.” Otherwise, these EPs would not be able to satisfy MU, as they would have denominators of zero for some measures.

NC Medicaid defines telemedicine as:

The use of two-way real-time interactive audio and video between places of lesser and greater medical capability and/or expertise to provide and support health care when distance separates participants who are in different geographical locations. A recipient is referred by one provider to receive the services of another provider via telemedicine.

Can I include encounters paid by Health Choice in my PV numerator?

Health Choice encounters may not be included in the numerator of the Medicaid patient volume calculation, except in the case of EPs who practice predominantly at a Federally Qualified Health Center (FQHC) or Rural Health Clinic (RHC). FQHCs and RHCs can include these as non-Medicaid needy in their numerator.

Can I include Family Planning encounters in my PV numerator?

Family Planning Medicaid encounters may not be included in the numerator of the Medicaid patient volume calculation, except in the case of EPs who practice predominantly at a Federally Qualified Health Center (FQHC) or Rural Health Clinic (RHC). FQHCs and RHCs can include these as non-Medicaid needy in their numerator.

We have a new billing NPI. For PV, do we report our new NPI or old NPI?

On the patient volume page in NC-MIPS, for practice billing NPI or group billing NPI, enter the NPI that you used as billing NPI on your Medicaid claims during your reported 90-day patient volume reporting period.

I attested to Program Year 2018 using a PV reporting period from calendar year 2018. When attesting to Program Year 2019, may I use the same 2018 PV reporting period?

Yes. So long as the PV reporting period is a consecutive 90-day reporting period in either: 1. the calendar year prior to the current program year (so if attesting to Program Year 2019 - that'd be calendar year 2018) or 2. the 12 months immediately preceding the date of attestation (so if attesting on August 1, 2019, that’s any 90 days between July 31, 2018 and July 31, 2019), it is a valid PV reporting period and you may use it!

Can I include my numerator encounters that were paid for by another state's Medicaid program?

Yes. Please submit a billing memo on your practice’s letterhead regarding this with your attestation. Include a break-out of Medicaid encounters by state. If you had both Medicaid-paid and zero-pay, you’ll need break out each category of encounter by state. You must include any identifiers (e.g., rendering and billing NPIs) that you used on claims for the other state(s). We will reach out to the other state(s) to verify the encounters you report.

How do I report Medicaid encounters that were billed through an LME?

If you billed any of your Medicaid claims through an LME for your encounters reported in your attestation, you will need to complete the behavioral health (BH) template and then email the completed template with your signed attestation to NCMedicaid.HIT@dhhs.nc.gov.

Click here for the BH template. There are two separate templates, one for individuals and one for groups. If you are completing attestations for your group and you are using group methodology for your patient volume, you may complete one group behavioral health template and submit that same group BH template with each attesting group member’s attestation packet.

Can I include Carolina ACCESS encounters in my numerator?

Encounters, defined as a unique patient on a unique day, with Medicaid patients for billable services may be included in the numerator. If you include in your numerator Medicaid encounters for billable services where no claim was submitted to Medicaid (because the visit was covered by the management fee), please submit with your signed attestation a memo on your practice letterhead reporting the number of Medicaid encounters that fall into this category. Be sure to keep this memo and the documentation from your auditable data source that was used to come up with your patient volume numbers in case of post-payment audit.

You cannot include system-generated management fees for Carolina Access -CCNC (ICN region code 80 on Medicaid claims). These are paid Medicaid claims but there is no encounter directly tied to this.

Can I include Children's Health Insurance Program (CHIP) encounters in my numerator?

In NC, we refer to Title XIX expansion CHIP as MCHIP (Medicaid CHIP). Per the Stage 2 Final Rule, as of October 2012, NC permits these encounters to be counted in the numerator of their patient volume calculation. CHIP encounters may be included in the numerator only if they are part of Title XIX expansion or part of Title XXI expansion. EPs are still not permitted to include CHIP stand-alone Title XXI encounters as part of their numerator.

Is my practice allowed to use group methodology to calculate patient volume if EPs are in different years of participation?

Yes. If the EP meets the criteria for using group methodology, they may use group methodology to calculate PV even if they are in different years of participation.  MU is based solely on the individual attesting EP and has no impact on the way patient volume is calculated. For more information on calculating patient volume using group methodology, please refer to the Patient Volume tab of the Program website.

Can patients participating in the special program where Medicaid pays their Medicare Part B premium be counted in the Medicaid-enrolled numerator?

No. Service must be provided to a Medicaid-eligible patient to be included in the numerator. Participating in a special program (like a limited Medicare Savings Program (MQB-B)) does not count.

Can EPs round their patient volume percentage when calculating patient volume in the Medicaid EHR incentive program?

To participate in the Medicaid EHR incentive program, EPs are required to demonstrate a patient volume of at least 30 percent Medicaid patients over a 90-day period in the prior calendar year or in the 12 months before attestation. The Centers for Medicare and Medicaid Services (CMS) allows rounding 29.5 percent and higher to 30 percent for purposes of determining patient volume. Similarly, pediatric patient volume may be rounded from 19.5 percent and higher to 20 percent. (CMS FAQ8037)

Do I need to use the same reporting period for PV and MU?

No, these are two distinctly different measurements, so it is not required to use the same reporting period. The MU reporting period must be a consecutive 90- or 365-day reporting period from the calendar year that is the same as the program year for which you're attesting (if attesting for Program Year 2019, MU data should be collected during calendar year 2019).

Can I report PV using incident to data in Program Year 2019?

No. Per the September 2016 Medicaid Bulletin, as of November 1, 2016 providers may not bill incident to. For Program Year 2018, EPs must select a PV reporting period that begins after January 1, 2017 (at the earliest), so incident to is not an option for Program Year 2019.

Can I include CAP/C, CAP/DA or CAP/CO encounters in my PV numerator?

Yes, as zero-pay encounters. According to a representative from the CAP programs, to receive services under either the CAP/C, CAP/DA or CAP/CO program, beneficiaries must be approved for CAP participation and enrolled in Medicaid in one of these approved categories: MAA, MAB, MAD, I-AS or H-SF. The PV numerator includes all billable services rendered on any one day to a Medicaid-enrolled individual, regardless of payment liability (this includes zero-pay claims); as such, encounters paid for by the CAP/C, CAP/DA or CAP/CO programs may be counted as zero-pay Medicaid encounters. For more information about the CAP/C and CAP/DA programs, please visit: https://medicaid.ncdhhs.gov/providers/programs-services/long-term-care/community-alternatives-program-for-children and https://medicaid.ncdhhs.gov/providers/programs-services/long-term-care/community-alternatives-program-for-disabled-adults. If you plan on including encounters paid for by the CAP programs in your zero-pay encounters, please submit a memo on your practice’s letterhead indicating how many of your zero-pay encounters are CAP program encounters.

Meaningful Use (MU)

Meaningful Use (MU)

What is Meaningful Use (MU)?

MU refers to the use of certified EHR technologies by health care providers in ways that measurably improve health care quality and efficiency.

The ARRA defines MU as:

  • Use of certified EHR in a meaningful manner (e.g., e-prescribing);
  • Use of certified EHR for electronic exchange of health information to improve quality of health care; and,
  • Use of certified EHRs to submit Clinical Quality Measures (CQM).

The goal is to bring about health care that is:

  • Patient-centered;
  • Evidence-based;
  • Prevention-oriented;
  • Efficient; and,
  • Equitable.

Am I required to attest to Stage 3 to participate in Program Year 2019?

Yes. Beginning in in Program Year 2019, all providers participating in the NC Medicaid EHR Incentive Program must meet all Stage 3 objectives and measures to meet Meaningful Use. Sources: CMS CFR § 495.24 and revisions to § 495.24 reflecting revised requirements for Program Year 2019 are located in the fiscal year 2018 Inpatient Prospective Payment Systems (IPPS) Final Rule (p. 38517).

Am I required to use a 2015 Edition of CEHRT to participate in Program Year 2019?

Yes. Beginning with the MU reporting period in calendar year 2019, participants in the Promoting Interoperability Programs are required to use the 2015 Edition of CEHRT pursuant to the definition of CEHRT under § 495.4. For the Promoting Interoperability Programs, the 2015 Edition of CEHRT must be implemented for an EHR reporting period in calendar year 2019, which will be a minimum of 90 days as established in this final rule. It does not need to be implemented on January 1, 2019. Please see the IPPS Final Rule for more information: https://www.federalregister.gov/documents/2018/08/17/2018-16766/medicare-program-hospital-inpatient-prospective-payment-systems-for-acute-care-hospitals-and-the#p-90

When EPs work at more than one location, are they required to use data from all locations to demonstrate MU for the NC Medicaid EHR Incentive Program?

An EP is required to attest with complete data from all locations equipped with certified EHR technology in order to demonstrate meaningful use.

Can an EP meet MU without having seen any patients during their MU reporting period?

No. An EP must have had performed at least one professional service during her/his MU reporting period and need to have met all meaningful use requirements to qualify for an EHR incentive payment.

How does the NC Medicaid EHR Incentive Program define a licensed healthcare professional for the purposes of meeting the MU objective, computerized provider order entry (CPOE)?

For the purposes of the NC Medicaid EHR Incentive Program, a licensed healthcare professional is one who has been recognized by an accredited authorizing entity as being capable to practice healthcare in North Carolina. It is the responsibility of the practice to regulate that only those employees who are authorized to enter orders into the medical record per state, local, and professional guidelines are doing so to meet the CPOE measure.

Please note, the order must be entered by someone who could exercise clinical judgment in the case that the entry generates any alerts about possible interactions or other clinical decision support aides. This necessitates that CPOE occurs when the order first becomes part of the patient's medical record and before any action can be taken on the order.

Do any North Carolina counties qualify for the broadband access exclusions?

No. There are three objectives that require providers to have broadband access; Objective 5 – Patient Electronic Access, Objective 6 – Coordination of Care through Patient Engagement and Objective 7 – Health Information Exchange. CMS offers exclusions and hardship exceptions for providers who face barriers in meeting meaningful use objectives that require broadband access and Internet connectivity for their locations and patients. However, there are no counties in North Carolina that do not have 4 Mbps of Broadband download speed, therefore, there are none that would qualify for the broadband access exclusions. For more information, see https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/2016_BroadbandAccessExclusionsTipsheet.pdf.

In calculating the meaningful use objectives requiring patient action, if a patient sends messages or accesses their health information made available by their eligible professional (EP), can the other EPs in the practice get credit for the patient’s action in meeting the objectives?

If attribution of the message is impossible (it absolutely cannot be determined who from the group practice sent it), it may be counted in the numerator for any provider within the group sharing the CEHRT who has contributed information to the patient's record, if that provider also has the patient in their denominator for the EHR reporting period. However, if the message is attributed to a specific provider, then it cannot count. The transitive effect applies to the Secure Electronic Messaging objective, the second measure of the Patient Electronic Access (View, Download and Transmit) objective, and the Patient Specific Education objective. (CMS FAQ12825)

Are providers subject to Medicaid penalties if they do not adopt EHR technology or fail to demonstrate Meaningful Use?

No, Medicaid does not have any penalty for not being a meaningful user, and no penalties will be made to Medicaid reimbursements in 2019.

Please see Session Law 2017-57 § 11A.5 for information on mandated deadlines that will require providers to have an EHR and connect to the state-designated health information exchange (HIE) as a condition of receiving state funds, including Medicaid funds.

Where can I find more information about CMS' Stage 3 and Modification to MU in 2015 Through 2017 Final Rule?

Please click here for the Stage 3 and Modifications to Meaningful Use in 2015 through 2017 (Modified Stage 2) Final Rule.

Please click here for a copy of the Program Year 2019 Stage 3 Specification Sheets.

More information about CMS' new Final Rule can also be found on CMS' Promoting Interoperability Program website.

Do I need to use the same reporting period for PV and MU?

No, these are two distinctly different measurements, so it is not required to use the same reporting period. The MU reporting period must be a consecutive 90- or 365-day reporting period from the calendar year of the program year for which they’re attesting (if attesting for Program Year 2019, MU data should be collected during calendar year 2019).

What are the exclusion parameters for Stage 3 MU's objectives 6 and 7?

On July 30, 2019 CMS announced they had updated the Program Year 2019 Medicaid EP specification sheets to clarify the requirements for meeting Stage 3 MU's objectives 6 and 7. The requirements state:

"An EP must attest to all three measures and meet the threshold for two measures for this objective. If the EP meets the criteria for exclusion from two measures, they must meet the threshold for the one remaining measure. If they meet the criteria for exclusion from all three measures, they may be excluded from meeting this objective."

Click here for the Stage 3 MU Objective 6 specification sheet.

Click here for the Stage 3 MU Objective 7 specification sheet.

What MU reporting period will I be required to use in program years 2019 - 2021?

The Fiscal Year (FY) 2019 Inpatient Prospective Payment System ( IPPS) final rule, released August 17, 2018, specified EPs may use an MU reporting period of a minimum of any continuous 90-day period in program years 2019 and 2020. 

On Aug. 2, 2019, CMS issued the Fiscal Year 2020 (IPPS) and the Long-Term Acute Care Hospital (LTCH) Prospective Payment System (PPS) final rule. This rule changes the minimum MU reporting period for returning meaningful users from a full calendar year to any continuous 90-day period in Program Year 2021.

I administer vaccinations in my practice. What do I need to do to be in compliance with the requirements for Stage 3 MU's Objective 8 Measure 1 (Public Health and Clinical Data Registry Reporting: Immunization Registry Reporting)?

To meet Objective 8 Measure 1 (Public Health and Clinical Data Registry Reporting: Immunization Registry Reporting), EPs who administer vaccinations must be in active engagement with the North Carolina Immunization Registry (NCIR). NCIR is capable of accepting the specific standards required to meet the 2015 CEHRT definition and has declared readiness to receive immunization data, so EPs can take an exclusion for this measure only if they do not administer vaccinations.

EPs who wish to participate in Program Year 2019 of the NC Medicaid EHR Incentive Program but who are not yet in active engagement with NCIR, must complete registration with NCIR within 60 days after the start of their MU reporting period. In Program Year 2019, an EP’s MU reporting period must begin no later than Oct. 3, 2019 to get 90 days of MU data in calendar year 2019. This means the last day an EP may complete registration with NCIR to meet MU in Program Year 2019 is Dec. 1, 2019, with the 90-day MU reporting period being Oct. 3, 2019 through Dec. 31, 2019.

To begin registering with NCIR, EPs should contact the NCIR Help Desk by phone at 1-877-873-6247 or by email at ncirhelp@dhhs.nc.gov. EPs who are not already in active engagement with NCIR should begin this process now if they wish to apply for Program Year 2019 of the NC Medicaid EHR Incentive Program.

Is there any additional information outside of the CMS specification sheet that provides additional clarity on how to meet Stage 3 MU’s Objective 5 Measure 1 in Program Year 2019?

The Centers for Medicare and Medicaid Services (CMS) has recently provided clarification outside of the specification sheet for their intent of Stage 3 Meaningful Use’s Objective 5 Measure 1. In an email sent to states on Oct. 29, 2019, CMS specified the purpose of Objective 5 Measure 1 is that eligible professionals (EP) must make a patient’s health data available and offer all four functionalities (view, download, transmit, and access through API) within 48 hours of the information being available to the EP.

Objective 5 Measure 1 reads:

For more than 80 percent of all unique patients seen by the EP:

  1. The patient (or the patient-authorized representative) is provided timely access to view online, download, and transmit his or her health information; and
  2. The provider ensures the patient’s health information is available for the patient (or patient-authorized representative) to access using any application of their choice that is configured to meet the technical specifications of the Application Programming Interface (API) in the provider’s certified electronic health record technology (CEHRT).

CMS is giving EPs flexibility on meeting the second part of Measure 1 for Program Year 2019 only.  EPs may meet the second part of Measure 1 if they:

  1. Have enabled an API during the calendar year of the reporting period;
  2. Make data available via that API for 80% of the patients seen during their reporting period;
  3. Provide those patients with detailed instructions on how to authenticate their access through the API and provide the patient with supplemental information on available applications that leverage the API; and,
  4. Maintain availability of the API, i.e., it can’t be turned on for one day and then disabled.

EPs should maintain all documentation for at least six years in case of post-payment audit.

Clinical Quality Measures (CQMs)

Clinical Quality Measures (CQMs)

How should a provider who upgrades from 2014 Edition CEHRT to 2015 Edition CEHRT or changes CEHRT vendors report a full year of eCQMs in 2019?

An EP does not need to have 2015 Edition CEHRT by the beginning of the calendar year (or the eCQM reporting period). The data that Medicaid EPs are required to report for eCQMs is a snapshot based on the data within the CEHRT, taken at the time of attestation, for the reporting period. Medicaid EPs are responsible for reporting exactly the data that their CEHRT produces. CEHRT should accurately calculate and report the eCQM data for the full reporting period, in accordance with the relevant certification requirements at 45 CFR 170(c). CEHRT vendors are responsible for making sure that their product can perform per the certification requirements.

The eCQMs are not actually calculated until someone runs a report.  For instance, the breast cancer screening measure: At the time that the EP runs the report, the CEHRT should go through his or her records and finds all the 50-74 year old women and how many of those had mammograms within the previous 27 months (taking exclusions into account).  At the time that the EP sees the patient and records her age and whether she’s had a mammogram, it doesn’t matter whether the CEHRT is able to calculate the eCQM.  That data are just being stored to the database.  As long as it is correctly calculating it at the point that it is reported, the results should be right.

May I report zeros in my Clinical Quality Measures (CQMs) denominator?

While CMS strongly encourages providers to report CQMs that are relevant to their patient population, zero is an acceptable result provided that this value was produced by certified EHR technology.

What if I’m having trouble finding six Clinical Quality Measures (CQMs) to report?

Clinical Quality Measures (CQMs) are determined by CMS, so providers must select six CQMs from the list of 50 to meet MU. Per CMS, "quality measures are tools that help measure or quantify healthcare processes, outcomes, patient perceptions, and organizational structure and/or systems that are associated with the ability to provide high-quality health care and/or that relate to one or more quality goals for health care. These goals include: effective, safe, efficient, patient-centered, equitable, and timely care."

For those providers experiencing difficulty selecting six CQMs relevant to their scope of practice, free assistance is available through the NC AHEC. They may be able to assist you in identifying CQMs that can be implemented into your practice workflow. There are nine regional AHECs, please find your county below to contact your local AHEC:

Area L AHEC - Shannon Cambra, shannon.cambra@arealahec.org, 252-972-6958. Serving Edgecombe, Halifax, Nash, Northampton, and Wilson counties.

Charlotte AHEC - Erin Cloutier, Erin.Cloutier@carolinashealthcare.org, 704-512-6052. Serving Anson, Cabarrus, Cleveland, Gaston, Lincoln, Mecklenburg, Stanly, and Union counties.

Eastern AHEC - Angel Moore, MOOREAN@ECU.EDU, 252-744-5221 (office) or 252-327-0207 (cell). Serving Beaufort, Bertie, Camden, Carteret, Chowan, Craven, Currituck, Dare, Gates, Greene, Hertford, Hyde, Jones, Lenoir, Martin, Onslow, Pamlico, Pasquotank, Perquimans, Pitt, Tyrrell, Washington, and Wayne counties.

Greensboro AHEC - Suzanne Lineberry, suzanne.lineberry@conehealth.com, 336-832-8025. Serving Alamance, Caswell, Chatham, Guilford, Montgomery, Orange, Randolph, and Rockingham counties.

Mountain AHEC – Leslie McDowell, leslie.mcdowell@mahec.net, 828-257-4459. Serving Buncombe, Cherokee, Clay, Graham, Haywood, Henderson, Jackson, Macon, Madison, McDowell, Mitchell, Polk, Rutherford, Swain, Transylvania, and Yancey counties.

Northwest AHEC -  Chris Jones, cjones@wakehealth.edu, 336 939-6737. Serving Alexander, Alleghany, Ashe, Avery, Burke, Caldwell, Catawba, Davidson, Davie, Forsyth, Iredell, Rowan, Stokes, Surry, Watauga, Wilkes, and Yadkin counties.

SEAHEC - Jessica Williams, Jessica.ReedWilliams@seahec.net, 910-667-9350. Serving Brunswick, Columbus, Duplin, New Hanover, and Pender counties.

Southern Regional AHEC - Donna Bowen, Donna.Bowen@sr-ahec.org, 910-678-0119. Serving Bladen, Cumberland, Harnett, Hoke, Moore, Richmond, Robeson, Sampson, and Scotland counties.

Wake AHEC -Lora Wright, Lowright@wakeahec.org, 919-350-0472. Serving Durham, Franklin, Granville, Johnston, Lee, Person, Vance, Wake, and Warren counties.

While CMS strongly encourages providers to report CQMs that are relevant to their patient population, zero is an acceptable result provided that this value was produced by certified EHR technology.

To review the list of Program Year 2019 CQMs, see the eCQI website.

I’m a returning meaningful user and I retired before the end of calendar year 2019. May I complete an attestation in NC-MIPS since I’ve collected my complete CQM data for 2019?

Yes, the CQM data collected from January 1, 2019 through your retirement date can be considered your complete data to meet the full-year reporting period required for CQMs for returning meaningful users, so you may submit an attestation for Program Year 2019 if you meet all other program requirements.

I retired without working all of calendar year 2019. Can I report the data collected during the time I worked as my full calendar year of CQM data?

Yes, there is no requirement that an EP practice for the full year.  If you retire or go on leave and has less than 12 months of data, that is still your complete data for the year. You may still meet MU if you meet the threshold for each measure and are using the required CEHRT Edition for the MU reporting period.

I took an extended leave from work in calendar year 2019. Can I report the data collected during the time I worked as my full calendar year of CQM data?

Yes, there is no requirement that an EP practice for the full year.  If you retire or go on leave and has less than 12 months of data, that is still your complete data for the year. You may still meet MU if you meet the threshold for each measure and are using the required CEHRT Edition for the MU reporting period.

I worked at one location with CEHRT for part of 2019 and one location without CEHRT for part of 2019. Can I report CQM data from just the location with CEHRT and still meet the full calendar year requirement?

An EP is required to attest with complete data from all locations equipped with certified EHR technology, and EPs who practice in multiple locations need at least 50 percent of their patient encounters during the reporting period to take place at locations with certified EHR technology (CEHRT). So, if only one of the locations where you worked had CEHRT, and at least 50 percent of your patient encounters were at the location with CEHRT, you can report just the CQM data from that location with CEHRT, even if you worked at the location with CEHRT for less than a year. The data collected at the location with CEHRT can be considered your complete data for the year.

If an EP practices at multiple locations, at least 50% of their patient encounters must occur at a location equipped with CEHRT. The EP should combine data for measures and CQMs across locations where possible, and report on measures and CQMs from the location with the greatest number of patient encounters when other locations chose different measures and/or CQMs.

I worked at two practices that both had CEHRT in calendar year 2019. Can I use a combination of CQM data from two different practices?

Yes, you can combine CQM data if both locations collected data on the same CQMs. You should combine data for measures and CQMs across locations where possible. But if each location collects data for different CQMs, you should only report on CQMs from the location with the greatest number of patient encounters. The CQM data from the location with the greatest number of patient encounters can be considered your complete data for the year.

All EPs should maintain for at least six years all documentation from the location(s) from which they are reporting. CMS’ guide for EPs practicing at multiple locations states that “The eligible professional should combine data for measures and CQMs across locations where possible, and report on measures and CQMs from the location with the greatest number of patient encounters when other locations chose different measures and/or CQMs.” 

If your MU reporting period is at multiple locations with a CEHRT, you’ll need to get, and combine, the data from multiple locations.

I worked at two practices that both had CEHRT in calendar year 2019. I only have access to my MU and CQM data from one practice. I have no access to any data, including number of patient encounters, from the other practice. Can I meet the full calendar year requirement for CQM data?

Because you will not be able to combine data from all locations with CEHRT or determine the location with the greatest number of patient encounters, you will not be able to meet the full calendar year requirement for CQM data, so you will not be able to attest for Program Year 2019.

An EP is required to attest with complete data from all locations equipped with certified EHR technology in order to demonstrate meaningful use.  If an EP is unable to obtain meaningful use data from a given location, the EP is still required to include patients seen during the reporting period at that location in the denominator of meaningful use objectives. If the EP is still able to meet all of the measures after including patients seen in the denominator of measures, then he or she will be able to successfully demonstrate meaningful use. Without meaningful use data available, the EP will not be able to include actions taken for those patients in the numerator of meaningful use objectives, which can negatively impact performance on measures.

I’m a practice administrator, and I have an EP who is leaving our practice before the end of calendar year 2019. Can we attest using the data we’ve collected while the EP was employed with us as a full calendar year of data for CQMs?

If the EP will not be moving to a practice with CEHRT, or if the EP will be moving to practice with CEHRT but will not have more patient encounters with the new practice than with your practice, the EP can decide to attest and assign payment to your practice as long as s/he meets all other requirements and as long as your location has CEHRT. The CQM data collected while s/he was employed with you can be considered their complete data for the year. The provider may choose where s/he wants to assign their payment.

Are there other resources for information about CQM reporting periods?

Yes, additional information is below:

Guide for Eligible Professionals in the Medicaid Promoting Interoperability Program Practicing in Multiple Locations https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/2016_EPMultipleLocations.pdf

https://www.federalregister.gov/d/2015-25595/p-472 Mod Stage 2/Stage 3 Final Rule

The Stage 3 Final Rule states the CQM reporting period will be a full calendar year for returning Meaningful Use EPs, and any continuous 90 days within the calendar year for EPs demonstrating Meaningful Use for the first time. Please see the following excerpt regarding an EPs inability to report a full calendar year:

https://www.federalregister.gov/d/2015-25595/p-472

Comment: We received many comments opposing the full year reporting period, indicating that it is very challenging and may add administrative burdens. Commenters also indicated the following areas of concerns that could impact the ability to demonstrate a full year of meaningful use:

• EPs change in place of service (POS).

• EPs joining a practice in the middle of the year.

• Ongoing software updates (for example, ICD-10).

• Difficulty in getting data from previous places of employment.

• Not enough time for the vendors and developers to make software updates.

• Timing of the data submission.

Other commenters stated full year reporting does not allow sufficient time for these practices to identify shortcomings in their adherence to meaningful use and implement corrective actions before the next reporting period.

Response: First, we understand the commenters' concerns and note that providers may consider applying for a hardship exception from the Medicare payment adjustments based on extreme circumstances outside the provider's control that contribute to their inability to meet the requirements of the EHR Incentive Programs. Second, we note that the thresholds of the measures themselves are designed to provide leeway for providers to adjust workflows and implementation as necessary during the EHR reporting period. With the exception of maintaining drug interaction and drug allergy clinical decision supports for the duration of the EHR reporting period, no measure has a threshold of 100 percent. We believe that system downtime could be expected in some cases for software or system maintenance, but providers may still meet meaningful use if they meet the threshold for each measure and are using the required CEHRT Edition for the EHR reporting period. Third, as noted previously, if a provider is fully implementing the requirements of the program, the workflows and implementation of the technology would not be limited to only 90 days, and thus a longer EHR reporting period should be feasible.

Additional documentation may be found in the 2014 Stage 2 Final Rule (Page 15): Comment: Some commenters suggested that for EPs practicing in multiple locations that meaningful use attestations should be limited to just reporting on meaningful use for the most prevalent location due to the difficulty in aggregating data across locations. Response: We continue to believe that for the core measures, aggregating data is not overly burdensome. We allow the numerators and denominators calculated by CEHRT to be summed across an EP’s various practice locations. Comment: We received request for clarification on what to do when an EP is practicing in multiple locations that select different menu objectives to pursue, and the EP does not control this selection. Response: An EP who does not have the same menu objectives implemented across each of their practice locations equipped with CEHRT would attest to the three menu objectives that represent the greatest number of their patient encounters.

May I attest to any of the CQMs listed on the eCQI website for Program Year 2019?

No. CMS has approved 50 CQMs for Medicaid providers attesting for the Medicaid EHR Incentive Program. Please click here to see the message from CMS and the CQMs that are available for providers attesting in Program Year 2019.

NC Medicaid EHR Incentive Payment System (NC-MIPS)

NC Medicaid EHR Incentive Payment System (NC-MIPS)

My NCID username and password work on all other Medicaid sites, including ncid.nc.gov, but I am getting an error when I try to login to NC-MIPS. What should I do?

If the EP has an account on NC-MIPS and has changed their NCID username since completing the First-time Account Setup, please update the provider’s NCID username in NC-MIPS using the NC-MIPS NCID Username Update Tool. For instructions on using this tool, please watch NCID Username Update Tool in NC-MIPS (Run time: 2:20).

If the EP is new to North Carolina and does not have an account on NC-MIPS, please complete the First-time Account Setup on NC-MIPS. For more information, watch Creating an NC-MIPS First Time Account Setup (Run time: 2:40).

For more attestation assistance, please refer to the Stage 3 MU Attestation guide (right side of NC-MIPS).

I am a proxy attesting on behalf of a large practice. May I use one login for all my providers?

No. All attesting EPs must have a unique login (their individual NCID username & password).

If I make updates to my attestation, do I have to re-print & re-send the signed attestation?

Yes. If the attestation is in any way altered or updated, you will need to re-print, sign, and send the update signed attestation. The EP's signature is authorizing that the information most recently submitted is true and accurate.

How do I withdraw and re-attest?

Please visit the NC-MIPS Portal at https://ncmips.nctracks.nc.gov/, click ‘withdraw’ on the status page. After withdrawing, click ‘proceed’ on the status page, address the discrepancy, and re-submit (previous data is saved) online. The attesting provider must then sign the revised attestation packet and email the signed packet to NCMedicaid.HIT@dhhs.nc.gov.

On NC-MIPS, what is the difference between the cancel and the withdraw buttons?

In short, the cancel button is used while an attestation is still in progress and the withdraw button is used after an attestation has been submitted through the NC-MIPS Portal.

The cancel button will be used when an EP realizes they are unable to meet program requirements for that year and do not want to proceed with their attestation. Selecting the cancel button will stop any correspondence from the NC Medicaid EHR Incentive Program for that year. After canceling an attestation, providers are still allowed to come back prior to the close of the program year in NC-MIPS and continue their attestation.

The withdraw button will be used when an EP has submitted their attestation but wishes to withdraw it from the validation process. This action may also be taken if an error is found on a submitted attestation. The user may withdraw the attestation, correct any information and re-submit for validation at any time. The information entered in the original attestation will be saved within the system, making resubmission easy for the provider.

I am receiving a warning message that I need to complete my registration with CMS. What do I need to do?

That message will populate if the CMS registration has not been fully submitted or if an EHR certification number was not entered during CMS registration.

To enter an EHR certification number on CMS' R&A system:

  1. Go to https://ehrincentives.cms.gov
  2. Click Continue
  3. Check the box, click continue
  4. Log in using the NPPES username & password
  5. Click on the Registration tab to continue
  6. Click on Modify in the Action column to continue
  7. Click on Topic 1 - "EHR Incentive Program"
  8. Click Yes at "Do you have a certified EHR?"
  9. Enter the EHR number
  10. Click Save & Continue
  11. Click Save & Continue
  12. Click Save & Continue
  13. Click on Proceed with Submission
  14. Review the information then click Submit Registration
  15. Click Agree

Please allow two business days for system updates.

To ensure all CMS registration information is fully submitted:

  1. Go to https://ehrincentives.cms.gov
  2. Click Continue
  3. Check the box, click continue
  4. Log in using the NPPES username & password
  5. Click on the Registration tab to continue
  6. Click on Modify in the Action column to continue
  7. Click on Proceed with Submission
  8. Review the information then click Submit Registration
  9. Click Agree

I tried updating information on CMS' Registration & Attestation (R&A) System, but after two business days the update is still not showing up on NC-MIPS. What's wrong?

Please take the following action(s) to ensure all CMS R&A system updates are submitted:

  1. Go to https://ehrincentives.cms.gov
  2. Click Continue
  3. Check the box, click continue
  4. Log in using the NPPES username & password
  5. Click on the Registration tab to continue
  6. Click on Modify in the Action column to continue
  7. Click on Proceed with Submission
  8. Review the information then click Submit Registration
  9. Click Agree

Please note, it takes two business days for any changes submitted through the CMS R&A system to become effective on NC-MIPS.

You should see the following Submission Receipt if you successfully submitted your updates on CMS' R&A system:

screengrab from Registration and Attestation System

If you have successfully submitted all updates on CMS' R&A System and after two business days you still do not see the change in NC-MIPS, please send an email to NCMedicaid.HIT@dhhs.nc.gov with a copy of the CMS Submission Receipt. In the email, please also include the provider's name, NPI, and CMS Registration ID and a brief explanation of the issue.

I submitted my registration on CMS' Registration & Attestation (R&A) System and the status indicates that my registration is pending state validation and has been sent to the state for review, but I haven’t received an email from the state. When will I receive an email from the state so I can begin my attestation for the NC Medicaid EHR Incentive Program?

EPs will not receive an email from the state each program year. Emails are only sent to those providers who have successfully attested at least once before Program Year 2016 in another state’s Medicaid EHR Incentive Program and are registering to attest with NC for the first time. If you have previously attested through NC-MIPS and have submitted an update through CMS for Program Year 2018, wait two business days for the update to be processed, then you may begin your attestation on NC-MIPS.

Please note, the status on CMS’ R&A system does not reflect the status of an attestation you submitted, or are working on, on NC-MIPS. To see the status of the attestation for the NC Medicaid EHR Incentive Program, please visit the NC-MIPS Status page.

I need to update my name so it's correct on CMS' Registration & Attestation (R&A) System. What do I need to do?

To correct your name on the CMS R&A System, you must go through NPPES.

Go to nppes.cms.hhs.gov and log in with your I&A user name and password. On the main page near the middle, you’ll see Manage Provider Information with your NPI record below. Click on the pencil icon to the right of your NPI record. Then you can change your name. After changing your name, do not click on Save and Return to the Main Page – this will not submit the change. You must go all the way through to the submission certification page then submit. You will see a thank you message with tracking information for the change you submitted and a notification email will be sent from NPPES to the contact associated with your account. Changes should take approximately two business days to be processed.

Please wait two business day after submitting the change with NPPES, then log in to the CMS R&A System and take the following actions:

  1. Go to https://ehrincentives.cms.gov
  2. Click Continue
  3. Check the box, click continue
  4. Log in using the NPPES username & password
  5. Click on the Registration tab to continue
  6. Click on Modify in the Action column to continue
  7. Click on Proceed with Submission
  8. Review the information then click Submit Registration
  9. Click Agree

Please note, it takes two business days for the change to become effective on NC-MIPS.

Please make sure that your name has been updated so it matches between CMS' R&A System, NCTracks and your North Carolina medical/nursing/dental license. For more information on name updates, please watch the webinar What to do When Your Name Changes (Run time: 2:32).

Payment

Payment

What safeguards are in place to ensure that NC Medicaid EHR incentive payments are used for their intended purpose?

Neither the statute nor the CMS final rule dictates how a Medicaid provider must use their EHR incentive payment.

After successfully demonstrating MU for the NC Medicaid EHR Incentive Program, will incentive payments be paid as a lump sum or in multiple installments?

EPs can receive up to six payments through the end of the program in Program Year 2021. EPs may receive $8,500 each year they successfully participate in the program, pediatricians may receive $5,667 each year they successfully attest.

Where can I find my incentive payment on my RA (remittance advice)?

An incentive payment can be found as a separate item on the RA after paid and denied claims in the “Payouts” section, before the Financial Summary page. RAs are available on the NCTracks Provider Portal.

Payment information will be posted under the 'Path to Payment' tab on the PProgram website. The payment spreadsheet will contain the provider NPI, payee NPI, the amount paid, the EFT date, and a CCN to reconcile the payment on their RA.

What if my EHR costs more than the incentive payment? May I request additional funds?

No. The NC Medicaid Incentive Program is not a reimbursement program. Maximum payments have been set by CMS. For additional information, please visit CMS’ Promoting Interoperability Program website.

Do recipients of NC Medicaid EHR incentive payments need to file reports under Section 1512 of the American Recovery and Reinvestment Act (ARRA) of 2009?

No. The Medicaid EHR incentive payments made to providers are not subject to ARRA 1512 reporting because they are not made available from appropriations made under the Act.

Are payments issued by the NC Medicaid EHR Incentive Program subject to federal income tax?

CMS notes that nothing in the HITECH Act excludes such payments from taxation or as tax-free income, so it is likely that payments would be treated like any other income. Providers should consult with a tax advisor or the IRS regarding how to properly report this income on their filings.

In general, there are three things providers need to know regarding taxes and the NC Medicaid EHR Incentive Program:

  1. If you assign your payment to a third party (such as your group practice), CMS is still obligated to report a payment to the eligible professional her/himself. The eligible professional will then bear a reporting obligation with respect to the assignment to a third party. CMS would not have a reporting obligation with respect to the third-party assignee unless CMS exercised managerial oversight with respect to, or had a significant economic interest in, the assignment.
  2. Recipients must include incentive payments as part of their gross income unless they receive payments as a conduit or an agent of another and are thus unable to keep the payments. For example, Dr. Smith works at ABC Healthcare and they use a 3rd party billing agency. Dr. Smith’s Electronic Funds Transfer (EFT) may get sent to the 3rd party billing agency and redirected directly to Dr. Smith. Be that the case, the 3rd party billing agency would not need to include the EHR incentive payment as gross income, but Dr. Smith would need to include the EHR incentive payment as gross income.
  3. To see the CMS reporting requirements with regard to eligible providers, see section 6041 of the Internal Revenue Code.

For specific provider questions, please call the Internal Revenue Service (IRS) toll-free at 800-829-3903.

How do I track an NC Medicaid EHR incentive payment?

Once a payment has been issued for an NC Medicaid EHR incentive payment, the Program posts to the program website under "Path to Payment" a spreadsheet with the provider NPI, the payee NPI, the payee name, the amount paid, the EFT date, and a CCN, which should make the payment easily identifiable on the remittance advice (RA), available on the NCTracks Provider Portal.

The incentive payment can also be found as a separate item on the RA after paid and denied claims in the "Payouts" section, before the Financial Summary page.

The "EFT effective date" given on the spreadsheet can be used to reconcile the payment against the 835 or RA.

An EP may check the status of their attestation at any time by logging onto NC-MIPS.

I attested for an incentive payment, but I entered the wrong payee NPI and the wrong person and/or organization was paid. What can I do to re-assign the payment or deal with tax liability?

Once a provider has assigned a payee on CMS’ Registration and Attestation System, has completed an attestation, and has been paid, NC Medicaid will not reassign the same payment to a different payee. If a provider has assigned the payment to an unintended payee, the provider will need to facilitate a transfer of the payment between the actual and intended payee.

The provider may request a corrected 1099 from NC Medicaid by sending a copy of their 1099 along with a W-9 for the group to NC Medicaid to request the incentive payment earnings be moved to the new (intended) payee’s tax ID. This will remove the incentive payment earnings from the actual (initial) payee and add the incentive payment to the new (intended) payee. Please note that corrected 1099s are mailed by NC Medicaid on April 1.

I attested for an incentive payment, but a payee other than the payee specified in CMS' Registration and Attestation System was paid. What can I do to re-assign the misdirected payment?

If a payee other than the payee specified in the CMS’ Registration and Attestation System was paid, please contact NCTracks. They will work with providers on a case by case basis to resolve the issue.

Will my incentive payment be a direct deposit or issued via check?

The payment is made via electronic funds transfer (EFT) to the account associated with the payee NPI/payee EIN given during attestation. Payments will be posted on a spreadsheet under the "Path to Payment" tab on the Program website. The spreadsheet will give the amount paid with the EFT date and CCN number, which should make the payment easily identifiable on the RA, available on the NCTracks Provider Portal. An incentive payment can be found as a separate item on the RA after paid and denied claims in the “Payouts” section, before the Financial Summary page.

Can a provider who has retired or opted out of Medicaid still receive a Medicaid EHR incentive payment?

In the Medicaid EHR Incentive Program, a provider must be a Medicaid provider during the MU reporting period. A provider who subsequently retires or opts out of a state’s Medicaid program is still entitled to the incentive payment. Note that the EP must assign payment to an NPI that is active in NCTracks.

I did not receive the payment listed on the Paid-to-Date spreadsheet. Who can help me?

If you are listed on the Paid-to-Date spreadsheet on the "Path To Payment" tab, you were approved for an NC Medicaid EHR Incentive Program payment and the Program team authorized issuance of payment to the payee NPI listed on your attestation. If you are unable to locate that payment, please contact CSRA (formerly CSC), the fiscal agent for NCDHHS, which operates the NCTracks system. You can reach them at 800-688-6696 or NCTracksprovider@nctracks.com. Request that the representative open a PEGA ticket to forward your concern to their Finance department. The Finance team can track electronic payments and provide information on when electronic funds transfer occurred and to what bank account the funds were sent. They can also provide the relevant page of the RA with details on payment.

Are providers required to assign their incentive payment to the practice where they work?

No. Any reassignment of payment must be voluntary as stated in CMS' Final Rule. Per 495.10(f), EPs are permitted to reassign their incentive payments to their employer or to an entity with which they have a contractual arrangement allowing the employer or entity to bill and receive payment for the EP’s covered professional services. Medicaid EPs may also assign their incentive payments to a TIN for an entity promoting the adoption of EHR technology.

Technology

Technology

What is the purpose of certified EHR technology?

Certification of EHR technology will provide assurance to purchasers and other users that an EHR system or product offers the necessary technological capability, functionality, and security to help them satisfy the MU objectives for the Medicaid EHR Incentive Program. Providers and patients must also be confident that the electronic health information technology (IT) products and systems they use are secure, can maintain data confidentially, and can work with other systems to share information. Confidence in health IT systems is an important part of advancing health IT system adoption and realizing the benefits of improved patient care.

For more information, please visit the Office of the National Coordinator's website.

Do providers have to contribute a minimum dollar amount toward their certified EHR technology to receive an EHR incentive payment?

No. Payments are not a reimbursement of cost so providers are not required to contribute a minimum amount toward the purchase or maintenance of their certified EHR technology in order to participate.

Where can I get answers to my privacy and security questions about EHRs?

The Office for Civil Rights (OCR) is responsible for enforcing the Privacy and Security rules related to the HITECH program. More information is available at OCR's website.

Must providers have their EHR technology certified prior to beginning the MU reporting period in order to demonstrate MU under the NC Medicaid EHR Incentive Program?

No. A provider may begin the MU reporting period for demonstrating MU before their EHR technology is certified. Certification need only be obtained prior to the end of the EHR reporting period. However, MU must be completed using the capabilities and standards outlined in the ONC Standards and Certification Regulation for certified EHR technology.

Must providers have their electronic health record (EHR) technology certified prior to beginning the EHR reporting period in order to demonstrate Meaningful Use under the Medicare and Medicaid Promoting Interoperability Programs?

No. Per CMS FAQ 2893, an EP or hospital may begin the EHR reporting period for demonstrating Meaningful Use before their EHR technology is certified. Certification need only be obtained prior to the end of the EHR reporting period. However, Meaningful Use must be completed using the capabilities and standards outlined in the ONC Standards and Certification Regulation for certified EHR technology. Any changes to the EHR technology after the beginning of the EHR reporting period that are made in order to get the EHR technology certified would be evidence that the provider was not using the capabilities and standards necessary to accomplish Meaningful Use because those capabilities and standards would not have been available, and thus, any such change (no matter how minimal) would disqualify the provider from being a meaningful EHR user. If providers begin the EHR reporting period prior to certification of their EHR technology, they are taking the risk that their EHR technology will not require any changes for certification.

How do I know if my EHR system is certified? How can I get my EHR certified?

The Medicaid EHR Incentive Program requires the use of certified EHR technology, as established by a new set of standards and certification criteria. Existing EHR technology needs to be certified by an ONC-Authorized Testing and Certification Body (ONC-ATCB) to meet these new criteria in order to qualify for the incentive payments. The Certified Health IT Product List (CHPL) is available online and as new products become certified and available, they will be updated on the site. Please click here for our two-minute video that shows you step-by-step how to pull the CEHRT ID number from ONC.

In Program Year 2019, EPs are required to use the 2015 Edition of CEHRT pursuant to the definition of CEHRT under § 495.4. For the Promoting Interoperability Programs, the 2015 Edition of CEHRT must be implemented for an EHR reporting period in calendar year 2019, which will be a minimum of 90 days as established in this final rule. It does not need to be implemented on January 1, 2019. Please see the IPPS Final Rule for more information: https://www.federalregister.gov/documents/2018/08/17/2018-16766/medicare-program-hospital-inpatient-prospective-payment-systems-for-acute-care-hospitals-and-the#p-90.

My EHR system is certified by the Certification Commission of Health IT (CCHIT). Does that mean it is certified for the NC Medicaid EHR Incentive Program?

No. The Medicaid EHR Incentive Program requires the use of ONC-certified EHR technology, as established by a new set of standards and certification criteria. Existing EHR technology needs to be certified by an ONC-Authorized Testing and Certification Body (ONC-ATCB) to meet these new criteria in order to qualify for the incentive payments.

Does Medicaid require providers to have an EHR?

Senate Bill 257 from the General Assembly of NC Session 2017 states the following:

 

 

 

 

 

 

 

 

 

 

 

 

 

As described above, if you are one of the three provider types [as listed in (1)] and have an EHR, only then are you required to connect to the NC HealthConnex by 6/1/18. If not, the current deadline to connect to the NC HealthConnex is 6/1/2019 [as stated in (2)].

Please read the Medicaid Bulletin for any upcoming changes/requirements that are applicable to Medicaid providers. Medicaid Bulletins are posted the first day of every month. They can be found here: https://medicaid.ncdhhs.gov/providers/medicaid-bulletins.

For more information about NC HealthConnex, please visit their website at https://hiea.nc.gov/.

Audits

Audits

Who conducts audits for the NC Medicaid EHR Incentive Program?

NC Medicaid EHR Incentive Program staff conducts audits.

I received an EHR incentive payment, am I subject to audit?

Yes, all providers who receive an EHR incentive payment are subject to post-payment audit. Providers must maintain all documentation supporting their attestations for at least six years post-payment as required by CMS.

EPs will receive an email from the Program investigators requesting specific information and documentation for a specified program year.

For a sample records request letter for a Program Year 2018 Modified Stage 2 MU audit, click here.

For a sample records request letter for a Program Year 2018 Stage 3 MU audit, click here.

For more information about NC Medicaid EHR Incentive Program audits, watch the Audit webinar!

What can I do to prepare my organization in case of audit?

After receiving payment, providers will receive an audit preparedness letter via email, to the contacts provided on their attestation.  This letter provides details on what type of documentation is requested for post payment audits.

An audit may include a review of any of the documentation needed to support the information that was provided in the attestation.

The primary documentation that will be requested for all North Carolina audits includes supporting documentation that the provider used when completing the attestation. This documentation must come from an auditable data source.

Documentation should include, at minimum:

  • Proof of patient volume numerator and denominator for the PV reporting period (report should include Medicaid ID numbers for Medicaid encounters and dates of service for all encounters);
  • The numerators and denominators for the CQMs (this documentation must come from the EHR, proof should be patient-level system generated documentation with dates of service);
  • Documentation to support the MU objectives/measures (this documentation must come from the EHR, the CQM report should be a list of all the patients in the numerator and denominator with dates of service);
  • The time the report covers;
  • Evidence to support that it was generated for the attesting provider; and,
  • AIU documentation proof can include copy of EHR contract, purchase order, cost associated with EHR installation, staff EHR training, software license agreements or data use agreements.

Please note, all PHI should be submitted via secured email. If the EP does not already have a secured email service, please email our Program Investigators at NCMedicaid.HITInvestigator@dhhs.nc.gov.

EPs must maintain all documentation for at least six years post-payment in case of an audit. The documentation should reflect the information provided in the attestation. If an EP fails an audit, the incentive payment will be recouped from the NPI that received the payment.

Where can I find additional information regarding the security risk assessment (SRA)?

Click here to watch an SRA webinar that provides insight into what will be required when submitting the SRA if selected for post-payment audit.

In addition to the SRA webinar, find below a list of several resources that are available to assist providers with conducting a security risk assessment:

Healthit.gov's Security Risk Assessment Tool

HHS' "The Security Rule" Website

HHS' Security Standards: Technical Safeguards

HHS' Security Standards: Administrative Safeguards

HHS' Security Standards: Physical Safeguards

CMS' Security Risk Analysis Tip Sheet: Protect Patient Health Information

If an EP fails an audit and the money is recouped (i.e. adverse audit for first year payment of $21,250), can the EP attest again for that same payment later in the program (i.e. can they re-attest for the $21,250)?

No. If the state has made a payment to an EP, and the EP later fails an audit, they must return the payment, and will be unable to re-attest to receive the first-year payment of $21,250. 

In other words, if the first-year payment is recouped, an EP will be unable to get another first-year payment. Similarly, if an EP has their second-year payment recouped, they are ineligible to receive another second-year payment.

Therefore, an EP that participates successfully for all six program years may receive up to $63,750; however, if the EP fails an audit and their first payment of $21,250 is recouped, the most the EP would qualify for during the life of the program is $42,500 ($63,750 – $21,250 = $42,500).

What is an auditable data source?

An auditable data source is defined as an electronic or manual system that an external entity can use to replicate the data from the original data source to support their attested information.

In the event of an audit, at a minimum, providers should have available documentation that supports a provider's attestation, including documentation that supports the provider's reported patient volume and each MU objective and measure (including CQMs).

Per the Final Rule, providers must keep documentation for at least six years following the date of attestation.

I received a notice on September 10, 2018 from Greenway Health regarding the time frame used to calculate View, Download, Transmit (VDT) and Patient-Specific within Prime Suite that may have led to reporting a higher result than achieved. What do I need to do?

You need to:

  • Keep a copy of this email from Greenway and any other related communication from Greenway, for six years.
  • Take screenshots of the applicable measures for your reported performance period prior to Oct. 5, 2018, for your records and keep for six years.

If selected for audit for Program Year 2017, you may need to submit, in addition to the standard documentation requested on the records request letter, communication from Greenway to the provider who attested (or to her/his practice), screenshots taken prior to Oct. 5, 2018 of the applicable measures for your Program Year 2017 reporting period, and revised performance measures retrieved from your EHR after Greenway’s fix.

For questions regarding audit, please email NCMedicaid.HITInvestigator@dhhs.nc.gov.

Contact Us

Contact Us

Providers should use the email listed below for all correspondence with the NC Medicaid EHR Incentive Program.

Email:                  NCMedicaid.HIT@dhhs.nc.gov

Note: The NC Medicaid EHR Incentive Program does not accept documentation via fax.