Medicaid EHR Incentive Program for Eligible Professionals

This transcript has been edited for spelling and grammatical errors.

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Centers for Medicare & Medicaid Services: Medicaid Electronic Health Records Incentive Program for Eligible Professionals:

Conference Call: Moderator: Diane Maupai:

February 18, 2011: 1:00 p.m. ET:

Welcome: ....................................................................................................................................... 2: Presentation slides 1 through 24: ................................................................................................... 3: Presentation Slides 25 through 45: .............................................................................................. 12: Question and Answer Session: .................................................................................................... 17: Question and Answer Session continued:.................................................................................... 30:


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Welcome Operator: Welcome to the Medicaid Electronic Health Records Incentive Program for

Eligible Professionals Conference Call. All lines will remain in a listen-only mode until the question and answer session. Today’s conference call is being recorded and transcribed. If anyone has any objections you may disconnect at this time. Thank you for participating in today’s call. I will now turn the conference over to Ms. Diane Maupai.

Ms. Maupai, you may begin. Diane Maupai: Good afternoon, everyone. My name is Diane Maupai; I’m with the Provider

Communications Group in CMS in Baltimore. I’m glad you can join us today. Let me start by apologizing for the problems we’ve had with getting you the presentation material. We’ve had some systems issues in CMS this week, so we weren’t able to post them as we had hoped. You should have received the presentation in an e-mail earlier today but in case you haven’t seen it the sender is medicare.ttt@palmettogba and the subject line is Presentation for Registration for the Medicaid EHR Incentive Program for Eligible Professionals. I hope you find it there and I hope you have it. But in case there are a couple of people that don’t; I’m going to read a link that contains the presentation and you have to forgive me because it’s a mouthful. It’s http://www.ampev1.com/customers/palmetto/medicaidproviderregistrationtraining.pdf and we will be posting the slide deck on the CMS Page after the call. I’m sure the issues we have will be resolved.

So moving onto content. Here at CMS we’re really excited that the first 11

States have launched their Medicaid EHR Incentive Program on January 3rd. We’re looking forward to other States launching during the spring and the summer. If you’d like to know when your State’s program will open for registration, please contact your State Medicaid agency or go to the Medicaid State Information Page on the CMS Website that is www.cms.gov/EHRIncentivePrograms.

http://www.ampev1.com/customers/palmetto/medicaidproviderregistrationtraining.pdf�

http://www.ampev1.com/customers/palmetto/medicaidproviderregistrationtraining.pdf�

http://www.cms.gov/EHRIncentivePrograms�


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Now I’m happy to introduce our speaker for today. Michelle Mills is the Technical Director in the Centers for Medicaid, CHIP and Survey and Certification.

Michelle Mills: Thank you, Diane. I’m really excited to talk to folks today about registering

for the Medicaid EHR Incentive Program here at CMS. Yesterday was the second anniversary of the Recovery Act, which contained all of the provisions in the HITECH Act, which authorized this program.

As of today, we have almost 4,000 eligible professionals in 11 States that have

initiated registration for this program. We have almost 600 hospitals in 47 States that have initiated registration for both the Medicare and Medicaid program. The Medicaid EHR Incentive Program payments to eligible professionals at this time, is almost $1.75 million. That’s to 82 eligible professionals in four different States. The Medicaid EHR Incentive payments to hospitals reached almost $30 million and that’s again in the first six weeks of the program that’s going to 20 eligible hospitals in three States. So with that, I’m going to go ahead and start the presentation. We will save time for questions and answers at the end of the call.

Presentation slides 1 through 24 We’re going to cover some basics for level setting today about program

eligibility in both Medicare and Medicaid for hospitals; eligible professionals and Critical Access Hospitals and then we’re going to get more into the registration details and eligibility verification. The reason we are going to touch on Medicare a little bit is because we’ve heard in our research here with external affairs that some providers are still confused about whether they’re eligible for Medicare or Medicaid or both and how that works and just understanding the basics of both programs and the eligibility requirement. So with that I’m on the third slide that has the Venn diagram and this includes eligible professionals for both programs. So the eligible professionals here in the middle are Doctors of Medicine, Doctors of Osteopathy or Doctors of Dental Medicine or Surgery. They are eligible for both the Medicare and the Medicaid EHR incentives so long as they meet all of the other program requirements.


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Furthermore the providers listed on the right, the Nurse Practitioners, Certified

nurse midwives, and Physician assistants in certain circumstances are eligible for the Medicaid EHR incentives but not the Medicare EHR incentives. Doctors of Optometry, Podiatric Medicine, and Chiropractors generally can only participate in Medicare and you can see those there on the left.

Moving to the next slide similar for hospitals, we expect most hospitals in this

program to be eligible for both Medicare and Medicaid. Unlike the eligible professionals, hospitals that are eligible for both Medicare and Medicaid can receive incentives for both programs. So again, to underscore that it’s important, Medicare and Medicaid eligible professionals, the slide we just looked at, they have to pick between Medicare and Medicaid. Hospitals who are eligible for both may receive an incentive under both programs. The subsection(d) hospitals and Critical Access Hospitals, which are also typically acute care hospitals under Medicaid all fall into this category of meeting the requirements for both so long as they have at least 10 percent of their patient volume coming from Medicaid. Additionally, Children’s hospitals, acute care hospitals in the territories and Cancer hospitals will all be eligible for the Medicaid incentive, but not Medicare.

Moving to the next slide some basics about the Medicaid eligibility for this

program, so as we mentioned on a previous slide you must be one of five types of eligible professionals so that was again the Physicians, the Certified nurse midwives, Nurse Practitioners, Dentists or Physician assistants when they practice in certain locations. You can participate if you’re one of those five eligible professional types, if you either have at least 30 percent of your patient volume derived from Medicaid or you practice predominantly in a Federally Qualified Health Center or a Rural Health Clinic where you have at least 30 percent of your patients coming from what we consider to be needy individuals. Needy individuals typically are Medicaid, CHIP, or individuals receiving services free or on a sliding scale based on income.

Additionally, there is one more caveat for pediatricians; in order to help

facilitate pediatricians’ participation in this program, they have a decreased patient volume threshold so pediatricians can participate in this program if


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they have at least 20 percent Medicaid patient volume, whereas that would be 30 percent for the other provider types. If pediatricians participate at this reduced patient volume threshold their incentive is also reduced, which we’ll talk about later. That provision doesn’t apply for practicing predominantly in the FQHC or the RHC and it doesn’t apply to the other eligible professionals. Pediatricians are regular physicians so of course if they have higher than 30 percent Medicaid patient volume they can participate at a full incentive as well.

Furthermore, all eligible professionals must be licensed and credentialed

appropriately in one of those five eligible professional types. You can’t have any Office of the Inspector General exclusions which are – it’s the Federal exclusion list that would prohibit you from receiving Medicaid money. And you must also be living – in other words – not on the Social Security’s Death Master File and you must not be hospital-based. Hospital-based means that you have more than 90 percent of your professional services being provided in either the inpatient or the emergency department settings of a hospital.

So more about Medicaid basics, we’re going onto the next slide. An Acute

care hospital must also have at least 10 percent Medicaid patient volume in order to participate. For Medicaid an acute care hospitals is a general short term stay hospital that includes the 11 Cancer hospitals and Critical Access Hospitals as well. We define the general short-term stay hospital as a hospital with an average length of stay of 25 days or fewer. The CMS certification number also known as the OSCAR number or the provider number must end in 0001 to 0879. Those are the same – that’s the same range typically for subsection(d) hospitals. It’s important to note that, for example, the Cancer hospitals while they fall in that range, they are not eligible for the Medicare incentive, which we’ll discuss here in a couple of slides.

And finally, Children’s hospitals have no patient volume thresholds. They

have at least half of their patient volume threshold coming from Medicaid anyway, but that requirement was not placed on them per the statute.

Going to the next slide and talking about some Medicare basics, as we

mentioned earlier, you must be a physician to participate in the Medicare


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program. The definition of physician as we noted on that first slide with the Venn Diagram, the physician definition is different between Medicare and Medicaid so in order to participate for Medicare you can be an MD, a DO, a Doctor of Dental Medicine or Dental Surgery, an optometrist, a podiatrist or a chiropractor. All of those types are considered a physician under the Medicare program and that’s consistent with our program here.

Additionally, in order to get an incentive you must have Part B Medicare

allowed charges. We know sometimes people meet the other requirements for the program, but they don’t have any Part B Medicare allowed charges. Additionally, just like Medicaid, they can’t be hospital-based to participate and they must be also enrolled in our Provider Enrollment, Chain and Ownership System also known as PECOS, which is the system that we pay providers under for Medicare and just like Medicaid they have to be living and not on the OIG exclusions list.

Moving to the next slide for Medicare hospitals, as we mentioned, the

hospitals for Medicare must be subsection(d) hospitals for Medicare. These are typically the acute care hospitals that are paid on the inpatient prospective payment system for Medicare. They must also be in the 50 United States or in D.C. so that’s why the hospitals in the territories aren’t qualified for this provision under Medicare. They could get Medicaid hospital incentives, but not Medicare. Additionally, Critical Access Hospitals are eligible for both programs as well. .

Moving to the next slide, so in order to register for this program, all providers

whether they’re hospital Medicare, Medicaid, eligible professional, need an NPPES web user account; NPPES is the system of enumeration that we use here at CMS for the National Provider Identifier (NPI), having an application in and an NPI generally does not mean you have a web user account. We’re using that web user account login information in order to log in for this program to make it easier on providers so that is necessary that they have a web user account prior to coming in to registering. If you don’t have one now you should go get one.


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Medicare EPs and all hospitals must also have a current enrollment record in PECOS – the way this impacts Medicaid providers; not Medicaid EPs, but Medicaid hospitals, is that they have to have a current enrollment record in PECOS. So they could check with us if they have questions about whether they have a current enrollment record in PECOS or they can call the contractor and ask questions.

Moving to the next slide, in order to get a payment, Medicare EPs and

hospitals must have Meaningfully Used certified EHR technology, Meaningful Use has been one of those things has been a big part of this program and so we’re not going to get into that today because we’re talking about Medicaid EPs and hospital registration, but we will talk a little bit about certified EHR Technology.

Also, Medicare EPs and hospitals have to attest to all the program

requirements, the Meaningful Use requirements and get an EHR Certification Number from the CHPL which we’ll talk about later in this presentation as well.

Slightly different Medicaid eligible professionals and hospitals don’t have to

demonstrate Meaningful Use in the first year of participation. So again Medicaid eligible professionals and hospitals don’t have to demonstrate Meaningful Use in their first year of participation to get an incentive. Instead, they can show that they adopted, implemented, upgraded or meaningfully used certified EHR technology. These adopted, implement and update requirements are much easier to meet than the Meaningful Use requirement and the intent is to offset the costs associated with getting the EHR technology in order to eventually meaningful use.

The Medicaid EPs and hospitals must also attest to all of the other program

requirements and we’ll talk more about that later too. So those are the program basics, hopefully it was some good level setting for everyone and now we’re ready to register, so what’s next?

So you’ll see a very – an image on the next slide of a very complicated

contraption. This is what we tried to avoid while we were setting up our


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system. I want folks to keep in mind that we’re going to go through a lot of caveats and exceptions and make it sound like this is what we put out but we are administering a program that will ultimately give out $30 billion in incentives for this program. Those are estimates over a 10 year period and we – there are some different checks and balances in place to make sure that we’re giving the right amount of money to the right providers.

So with that on the next slide, we tried to cut through as much red tape as

possible to make this program easy to use for providers so they can register, attest, and get paid.

So moving to the first slide, talking about registering, attesting and getting

paid for Medicaid; States with launched programs--so those are the 11 States that Diane mentioned at the beginning of this presentation, the EPs and hospitals can go to the CMS EHR Incentive Program Website, click on the Registration Tab and complete the registration. Again, when you get there, you’ll need your NPPES or NPI web user account login information to access the system. After you complete all of the registration information at the CMS site, you need to go your State’s website and complete the eligibility verification. We’re going to go through this in a little bit more detail later but the States will ask you questions about your patient volume and whether you have been sanctioned and how you’re licensed and so on. Then after that States will pay you no later than five months after you register; most are paying sooner. Kentucky and Oklahoma, two of our first States to launch their program, paid providers in that first week.

Kentucky saw two hospitals receive payments totally approximately $5

million on that first Wednesday after we launched the program and Oklahoma paid a group practice in Oklahoma as well for two eligible professionals at that practice.

So moving to the next slide, you can see what the first page looks like of the

CMS Registration and Attestation System. This is the first – when you go to that page, this is the first thing you’ll see. You aren’t yet asked for your login information, gives you some general information about the site, additional resources, you’ll see throughout the site, we refer you back to the CMS


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Website if you have any questions. Hopefully, your questions can be answered there.

There’s a drop down menu both for eligible hospitals and eligible

professionals here that show you more information about what it means to be one of those –in one of those categories.

Moving to the next slide, this is the first login page. This is where we

mentioned that you’ll use your NPI web user account information and password to log into the system. It is not appropriate to share that information with other individuals in order to register on your behalf. At the end of this, these slides will show you the one where you’re attesting to providing sure and accurate legal information under your name. If somebody does that on your behalf, you’re still liable legally for everything that is contained in this document.

Moving to the next slide, this shows you the tabs that will guide you through

each part of the registration process. The Attestation Tab is not relevant for the Medicaid eligible professionals, so you won’t need to use the attestation tab. That will be for the Medicare eligible professional and hospitals, and hospitals that are dually eligible for both Medicare and Medicaid.

The Status Tab will tell you throughout the process where you are. So if your

registration file is sent to the State for validation or eligibility verification it will say that in the Status Tab. If you’re expecting to receive a payment, it will say that you’re payment is being processed so that’s a good place to always check in this program to see where you are in the process. Finally, the Account Management tab allows you to do some higher level administrative management.

The next slide shows you the registration instruction screen. This is the next

thing you would see after you login. It gives you some general information about different actions that can take place. So of course you can register, you can modify a registration, you can cancel a registration if you decide you did not want to be considered to this program; however, it’s worth noting that if you come in and register and you don’t cancel your program, your


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information will be sent to the State and could still receive a payment. So if you’ve accidentally provided information that was incorrect you would need to go back and either modify or cancel your registration. You can reactivate a registration after it’s been cancelled and finally you can resubmit a registration as well.

Moving to the next slide, this shows that you’re registering for the program –

this slide here says you’re resubmitting your information just to show you a difference and how that would look if you selected that. It shows that this individual has already completed all of the different areas of registration which includes general information, personal information, business address and phone and then you would click again submission there at the bottom.

It’s important to use the buttons at the bottom in order to navigate through the

site as well and not use the back button; we think it’s pretty typical for folks when they’re registering for things like this.

The next slide shows you what it would like as you’re selecting between

Medicare and Medicaid for eligible professionals. So if you select the Medicaid button, you would get different information than if you select the Medicare button. This slide shows you if someone has selected Medicare but the field that we want to point to at the bottom here is, Do you have a certified EHR? And the answer would be yes or no. If you select no, it does not stop you from registering, you can register without having a certified EHR; however, at the point of attesting for the program either in Medicare or for Medicaid you do need to have that information. So, at some point before you get a payment you do need to have that. You don’t have to have it at registration so if you’re interested in this program today as a result of this call and you decide to go and register but you don’t yet have certified EHR technology that’s fine, you can still go this far and say no I don’t have that and it’s not a problem. That field there at the bottom doesn’t open up if you say no.

Moving to the next slide. This is what it looks like if you select Medicaid;

you’d hit apply and you’d see that the Medicaid State or territory field opens up. Currently for eligible professionals, the 11 States that have launched their


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programs to CMS so that means they’ve met all of our program requirements and they’re ready to accept your information and make a payment to you, those 11 States will be in that list for right now. You can click the link next to that; this says “Why isn’t my State here?” if you want to look at a list of known launch dates for your State.

So for example, I’ll use Maryland because that’s where we are right now.

Maryland hasn’t launched their program yet. So if I’m provider in Maryland and I don’t see Maryland listed there in the Medicaid State territory drop down box I would click on “Why is my State not here?” and then that would take me to a page that shows me when Maryland intends to launch their program. We have the best information that we have at any given time we update that State monthly. Some States are very specific that they’re going to launch on June 1, 2011; other States give timelines like fall of 2011, or there were a couple that had no known information.

Next, you would select your eligible professional type so that would be the

five that we talked about earlier and then you would answer Do you have a certified EHR? Yes or no. If you select yes you will be asked for what the certification number is. We’re going to talk a little bit more about that at the end of the presentation.

The next slide shows you what the registration process looks like for

Medicare. It’s important to note that this information is derived from current Medicare payment information and the reason we wanted to show this to you is because we don’t have that information for Medicaid eligible professionals when they register for this program. What instead is listed are text fields so you would enter where you want your provider – where you want your incentive payment to be sent and then the State would validate that. On the Medicare side we do that here. We will validate that against our current files but anything you enter here will be sent to the State. The State is then responsible for making sure that your Tax ID number and your National Provider Identification number selected for payment match each other in a way that makes sense for their system.


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So if you came in and you worked at a group practice and you gave us, you know, your cousin’s sandwich shop down the street, for your incentive payments to be sent to. The State would say wait a minute, we don’t have that relationship on record, let’s look at that a little bit more closely so they would reject that. However, if you work at a group practice and your practice receives Medicaid payments all the time, you use the correct NPI and Tax ID number combination no problem the State should send you an incentive payment at that Tax ID number.

Moving to the next slide, this is the legalese I talked about at the beginning so

you as an individual who registered for this program using the NPPES web user account information provided all this information so far and you’re saying that you agree and that you are legally on the hook for that information. So it’s important to keep that in mind. Again, we want to point out, we’re not encouraging folks to share their user ID and password with anyone else to register on their behalf. CMS is looking at adding functionality hopefully this spring that will allow someone to do that on your behalf but we have not added that yet so until that is in place please don’t share user names and passwords.

So at the point you click submit and agree to the legalese you move onto the

next. At that point going out behind the scene we’re processing your information to make sure that we think you’re eligible. So for example, we’ve checked the Death Master File, we’ve checked the OIG exclusions list, Medicare has checked a number of other things in the Medicare file and this person had a failed submission that means that they were probably on the Death Master File or the OIG exclusions list or something else and we’re getting some extra information about what steps to take there. We’re going to show you in a couple of slides what a successful submission looks like as well, so don’t worry. And then you’ll see at the bottom you have a Registration ID for tracking purposes. So if there are questions we do have a helpdesk and you can talk to them too and you would need that Registration ID to help expedite that process.

Presentation Slides 25 through 45


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Moving to the next slide, we start looking at some eligible hospital slides that would be different from the eligible professional slides. So for one, hospitals have to enter their CMS Certification Number. Eligible professionals don’t have a CCN. This is – again, the same thing as a provider number, your OSCAR number, so that is entered here and that would help us identify which hospital is actually signing up for the program according to our system.

Moving to the next slide, as we mentioned earlier, hospitals can register for

either Medicare, Medicaid, or both Medicare and Medicaid in the cases that they’re eligible for both programs. So in the case here, if they – we’ll see on the next slide what happens if they select both Medicare and Medicaid. But again, you can see that they have to also say “Do you have certified EHR technology?” yes or no, and then provide that information if they have it.

Moving to an – I’m sorry, it’s also important to mention on this slide that if

you are a hospital that is eligible for both Medicare and Medicaid. And so if you look at the program requirements and you say yes we fall into that bucket for both; we have the 10 percent Medicaid patient volume where either a subsection(d) or a Critical Access Hospital, no problem we meet the requirements for both. You should register for both. Just because you think oh, we’re just going to get the Medicaid incentive early in 2011, and then maybe come back later and apply for the Medicare incentive later in the year and we’ll just apply for Medicare then, you’re still eligible for both Medicare and Medicaid and that’s the field you need to select.

Moving to the next slide, this shows you what happens when you select both

Medicare and Medicaid. Similar to eligible professionals you have to then select a State. Unlike eligible professionals, that drop down menu contains all of the States and territories that might launch a program. We do expect all States and territories eventually to launch a program, but this list will have all of them, even if they’re not in that group that’s already launched their program.

So again, I’ll use Maryland as an example, let’s say I’m Johns Hopkins

Hospital I come in and I say I’m eligible for both Medicare and Medicaid then I select Maryland from that drop down menu? What happens next is that I


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will still be processed for my Medicare payment this spring when I can come back and attest and so on for the Medicare program. But my Medicaid file, for the hospital will be on hold until the State launches their program. So say Maryland comes along in October and they launch their program. As soon as we flip the switch for them to launch their program, they’ll receive Johns Hopkins’ files and they need to make a payment to them as well.

So for hospitals, if you select both you also have to select the type. So again,

that might be, you know, Acute Care Hospital and subsection(d) hospital for the two programs. And then again you see at the bottom the certified EHR, this person said no so that field is not open. So this is what a successful submission screen looks like. You’ll note that it says you’ve successfully registered for the EHR Incentive Program. It gives you some other information.

The important step here for Medicaid providers is that you are not done with

the process. You do have to go to your State’s site and finish your eligibility verification. You’ll notice in these slides we didn’t see anything about patient volume or practicing predominantly so the State asks you all of those questions. The reason is that those questions can vary in terms of the data sources the States are using or any other modifications they’ve made to their program in order to increase eligibility. So States will take a look at that.

Our files are sent nightly, so we say after 24 hours please continue the

process. If you try to go straight from the successful registration screen to your State’s site, they won’t have your information yet. You do need to wait a day and then go back. States will also be reaching out to you to make sure that there’s some continuity between that process.

Again at the bottom here, you see the Registration ID number, it’s important

to keep that tracked. The most important thing about this screen, besides if you’re Medicaid provider you’re not done, is that we are not sending you an e-mail confirmation telling you, hey, we received your registration, you registered for this program.


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Like if you go on Amazon or Zappos and buy some shoes, you immediately get a confirmation that they received your submission and that your shoes are on the way. In order to get this program up and running in January, there were some things that we weren’t able to enable and that was one of them. So while in the long term of the program, we do expect to be able to send e-mail confirmations in the future. We’re not doing that right now, so you do need to take an electronic screen shot of this or you need to print out this page so that you have it for your record.

Moving to the next slide, so as we mentioned, if you’re a Medicaid provider

you need to go to your State process in order to finish the program requirements. So we have a couple of slides here from the State of Michigan’s EHR Incentive Program to show you generally what it looks like when you go to the State. It’s generally a similar look and feel to what we were looking at here for the CMS site. Here you can see Michigan has received their file from a – for Ellen Johnson and has pre-populated all of the information they have on that provider so Michigan has information based on the National Provider Identifier as well. They’ve brought in some additional information as well as everything that was sent in the file from your registration with the Federal site.

You could see over here on the right, they have tabs for how to get through

their process and the things you need to answer as well as some general tabs at the top, too.

Moving to the next slide you’ll see where they’re asking about some different

program nuances so “Are you a pediatrician?” They’re asking that because they’ll have different patient volume requirements for being a pediatrician. “Are you a Physician assistant?” Physician assistants are only eligible on certain circumstances so they’re trying to figure out do we need to ask more questions of this provider. Then at the bottom here, you could see where they ask questions about the patient volume requirements and so on.

Moving to the next slide just like the CMS site, there’s an attestation site

where you will have some legalese where you were saying, yes, I agree to everything that I have submitted here, it’s true and accurate and your penalty


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is tar and feathering and all kinds of other things that the feds might do to you if you provide wrong information. So then – and you’re considered registered. Your registration is complete with the State, too. What happened here is the State then begins processing your eligibility information using the data sources they have available to them. So for example claims data, encounter data, et cetera, to make sure that you met all the program requirements.

Some States had really great systems for doing this. They were able to

automate this process very quickly. Kentucky, great example from the beginning; they’re automating a lot of this so they can make provider determination over a 24-hour period and turn out a payment very quickly as well. Other States had older systems and they weren’t starting from the same starting line on this, so it might be a little bit slower to verifying some of these requirements for providers. So depending on your State, you may receive a payment very, very quickly or it might be up to five months.

The next slide we talk about the Certified Health IT Products List or what we

call the CHPL (or “chapel”). This site is run by the Office of the National Coordinator who is in charge of making sure that the products out there are certified to meet Meaningful Use. You do need to go to this site in order to get a number from the CHPL in order to plug that back number back in the CMS registration site.

So let me give you an example. Let’s say I have an Epic Electronic Health

Record system and I have a couple of different modules like for e-prescribing in order to meet the Meaningful Use requirement. All of this is products that need to be entered here at the CHPL site and then you’ll get a unique number at the end that says that this collection of technology will meet Meaningful Use and then you’ll use that number on the CMS site.

I just want to emphasize that this was not – your vendor may have a

certification number as well and that’s different; that’s not the same thing.


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We’ve got one of our CMS experts on the line to answer questions about that as well who’s worked quite a bit on the issues related to the CHPL. So Larry Clark will be able to answer some questions later on that.

Finally, the last slide, this goes over some resources for you. We tried to

make our website as helpful as possible. We have Frequently Asked Questions, we have an Eligibility Wizard that’ll allow you to plug in some very basic information to see if you might be qualified for this program. We have our EHR Information Center phone number on here. Regional Extension Centers that are run through grants from the Office of the National Coordinator are also looking forward to helping providers get to Meaningful Use. They only work with certain provider practices that are the primary care oriented and so on. So that wouldn’t necessarily apply to all of the Medicaid EPs or hospitals.

And finally, our Final Rule is out there for anyone who wants some great

bedtime reading. We have a very long final rule that goes through all of these requirements and you too can be an expert on this program.

So with that, I’ll turn it back over to Diane for questions and answers. Diane Maupai: Thanks, Michelle, for a great presentation. Sarah, could you please open the line for questions. Question and Answer Session Operator: We will now open the lines for a question and answer session. To ask a

question please press star followed by the number one on your touchtone phone. To remove yourself from the queue please press the pound key. Please state your name and or organization prior to asking a question and pick up your handset before asking your question to assure clarity. Please note your line will remain open during the time you are asking your question so anything you say or any background noise will be heard in the conference. Your first question comes from the line of Tim Walters. Your line is open.


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Tim Walters: Thank you, this is Tim Walters I work in Citizens Memorial Hospital in Bolivar, Missouri. I’ve got two different questions concerning the Medicaid eligible professional criteria, the 30 percent criteria. We have both Rural Health Clinic physicians as well as other physicians that are not practicing in RHCs. First for the ones who are not in our RHCs, I know that when measuring the Medicaid volume we have to exclude patients under the CHIP Program from the numerator, we’re not aware of a way to do that with the information we have and I don’t know is that – how do we determine which patients have CHIP and which patients are under, I guess, traditional Medicaid.

Michelle Mills: Sure, thanks Tim that’s a really great question. So I want to clarify a couple

of things first. One is that any of your physicians or other eligible professionals that are considered hospital-based so in other words more than 90 percent of their professional services were provided in an inpatient or emergency department setting will not be eligible for this program. Secondly, the folks that work in the Rural Health Clinic they don’t have to meet the Medicaid patient volume requirements they can meet the needy individual patient volume requirements in order to qualify, which is much easier because the payer sources can be Medicaid, CHIP or folks that are receiving sliding scale or free services based on income.

Finally, so these other professionals that do need to meet the Medicaid patient

volume requirement, you’re asking how do you figure out if a client has Medicaid or CHIP as their payer source in order to count them in your numerator for patient volume. This is a complex question, so in our Final Rule we said that when the program is authorized under a section 1115 Demonstration Waiver then under Title XIX, I’m sorry, Title XIX is Medicaid. When a CHIP Waiver or an 1115 Waiver is authorized like that under Title XIX they can be included in the patient volume numerator. However, most Medicaid programs are not authorized that way. We’re looking in the future about ways you can be more flexible with that process but right now what a lot of states are doing is they’re saying, you know, you’re in Jefferson County Missouri and Jefferson County has 20 percent of their kids are Medicaid and 10 percent of their kids are CHIP so you need to


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apply those values to any kid you have in Missouri HealthNet Program in order to get an eligibility determination.

So they’re applying the county or State level proxy values to the individual

providers because the payment source will often be unknown by the provider especially in these programs that has CMS eligibility or a continuous eligibility programs. We know that in most case I’ve tried to make that process as easy as possible for both the beneficiaries and the providers so that will usually be the case. Your State’s State Medicaid Health IT plan, which is something they require to submit to us for review and approval should address this issue so I recommend contacting your State Medicaid agency – Missouri has a website, I would check out their website and see if they define this a little bit better in terms of how you should get to that determination.

Tim Walker: All right, we’ll check with the State on that one. The other one is more

specific to our records for our Rural Health Clinics and we have several of them, 10 of them to be specific. We have obviously a lot of data that we keep on the patients and we are going through, we’ve been able to track down the Medicaid data including CHIP and that’s not been a problem. For the uncompensated care patient population within our system we’ve been able to identify those in the aggregate for all of our Rural Health Clinics we haven’t been able to split that down to the clinic level in other words we know for all 10 rural health clinics just about three percent of our patient volume is for uncompensated care service with individuals who meet sliding scale discount policies or, you know, indigent care et cetera. What we’re trying to do is determine can we use that overall factor for the Rural Health Clinics across all the clinics to measure for our providers as opposed to manually going through the records to try and determine which patient might apply to which clinic.

Michelle Mills: You would need to work with your State on that to see how they would like to

operationalize that in your circumstances. Tim Walker: OK, so just work with State on how they will implement that, OK. Michelle Mills: It’s been our experience that the State staff that work on the EHR Incentive

Program are just outstanding and they’re bending over backwards they want


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this money in providers’ pockets and they will work with you as much and often and as fast as possible in order to get your questions answered and they often send them back to us as needed, too.

Tim Walker: OK thank you. Michelle Mills: You’re welcome. Operator: Your next question comes from the line of Todd Foyet, your line is open. Todd Foyet: Yes, I was concerned with the issue of certification of the EHR. If the EHR

meets certification for 2011 and 2012 but is not updated to meet certification for 2013, what would be the process or what would be the events that would occur for someone who has applied?

Michelle Mills: So Larry Clark is our CMS point person, our subject matter expert on the

certification requirements. Larry, can you answer his question about what happens when a provider receives certification for the first two years of the program and then what happens in 2013.

Larry Clark: Well, right now we’re working through the issues of what Stage Two would

look like so that may or may not change but if there is a need to re-certify a system that will be announced later.

Michelle Mills: OK thanks Larry. Todd, does that answer your question? Todd Foyet: Just to clarify you may not need to recertify then as long as – for example,

we’re using Epic, which is currently certified so if they don’t meet the certification requirements or if there is no need to re-certify in 2013, we’ll discontinue on with the process.

Larry Clark: If you go to the CHPL and you put that product in you will receive a CMS

EHR Certification ID Number that will tell you if that product is in fact certified for this program.

Michelle Mills: Thanks, Larry and Todd. Thanks, Todd. Todd Foyet: Thank you.


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Operator: Your next question comes from the line of Donna Garwood, your line is open. Donna Garwood: Thank you, can you hear me. Michelle Mills: Yes. Donna Garwood: OK, I’m asking this question on behalf of one of the hospitals in Kansas and

so I’m just going to read what’s written for me. Oh, and I am Donna Garwood and I’m the HIT Regional Extension Center Educator for the State of Kansas. This hospital is aware that they will be purchasing a certified electronic record system that will be capable of producing al the Meaningful Use measures for them for reporting. The question is, specifically we have a certified gender and all of the software required to meet all of the objectives that we plan to use to qualify for Meaningful Use. We have not, however, purchased the software that is available from the vendor that that we are not planning to use to meet the stage one requirements, must we purchase modules that will not be used for another one and half years.

Michelle Mills: Donna, I’m going to ask you to follow up with ONC because this – we really

need to get to the questions for this presentation that relate to registration on the Medicaid requirement.

Donna Garwood: I’m sorry. Michelle Mills: So if you could follow up with ONC that would be great. Donna Garwood: All right. Thanks. Operator: Your next question comes from the line of Linda Seville. Your line is now

open. Linda Seville: This is Linda Seville from Stormont-Vail Healthcare in Kansas. The question

about the payment; OK, right now when we’re not eligible or can even register in Kansas for the Medicaid but if were to choose just for the professional side for the Medicare and let’s say we don’t register until maybe June, are we going to get payment from January 1st through the whole year or does it start after you register?


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Michelle Mills: So Linda thanks for your question. You’re correct, the Medicaid program in

Kansas hasn’t launched yet. I don’t want to get too far into the Medicare requirements today, we’re just covering the Medicaid topics, we didn’t bring any of our Medicare subject matter experts and I might say something that’s wrong and I don’t want to put incorrect information out especially since we’re having a transcript and a recording so we do plan our follow-up calls about Medicare registration. We have lots of information on our website as well and we hope that you’ll attend when we have that Medicare call.

Linda Seville: OK. Well, for the Medicaid I’m assuming that – because it’s not even

available it’s going to go back for the whole year for payment. Michelle Mills: So if Kansas launches –- it’s not based on a period per se so the difference

between Medicare and Medicaid here is that for Medicaid you receive a flat incentive payment in your first year so you receive 21,250 unless you’re a pediatrician participating at a lower patient volume and then you get two thirds of that amount. So generally the 21,250 is a discrete number for Medicaid. For Medicare, the incentive is based on your Part B allowed charges up to a certain amount so, when you’re asking about what point in time would you get paid during the year, it depends on an accrual of your Medicare charges but I definitely don’t want to get into that today. For Medicaid if Kansas launches their program in, you know, June in this year you would get the same amount as if they had launched in January and I think maybe that’s what you’re trying to get at; it won’t impact providers.

Linda Seville: OK, so Medicaid it won’t impact and I need to wait to find out about

Medicare, thank you. Michelle Mills: You bet. Operator: Your next question comes from the line of Ezequiel Sandoval, your line is

now open. Ezequiel Sandoval: Hello. This is Ezequiel Sandoval with Infinite Consulting Services in

Northern California. I have two questions; one for Critical Access Hospitals you mentioned that one of the requirements is the length of stay less than 25


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days. If you could just clarify quickly, is it 25 or 21 days and are long-term care beds or distinct part bed that’s included in that calculation.

Michelle Mills: Two things on this, one is that I just want to clarify that you’re asking about

the Medicaid eligible hospital requirement for acute care hospitals that they have an average length of stay as 25 days or fewer. Critical Access Hospitals we believe also under that bucket because they have certification requirements that require that they have length of stay of 96 hours or fewer so they are processed pretty quickly in Critical Access Hospitals and we don’t expect them to have a problem meeting that. In terms of the additional bed days it depends on how they complete their cost report. We do have an FAQ on our website that gets into more detail about that.

Ezequiel Sandoval: Yes, excellent, thank you that does answer that question. The other

question has to do with the hospital-based providers 90 percent calculation, is that calculated based on the number of encounters or the number of charges, 90 percent of the charges that that provider performs in the hospital.

Michelle Mills: That’s a very timely question. We’re in the process now of getting an FAQ

put on our website that addresses that. I want to point out that with respect to Medicare and Medicaid there are different requirements for how a hospital-based eligible professional determination is made, for Medicare eligible professionals it’s based on their Medicare claims, for Medicaid it would be based on their Medicaid claims as well but not just the claims that they’re in and a State has a lot of managed care so since 70 percent of our Medicaid program nationally is managed care we also need to take a look at encounter data so most States will have that determination made on the basis of combining the encounters and claims data for Medicaid in order to determine that.

I just want to check in with Larry Clark who’s on the line and see if he has

anything to add to that. Larry Clarke: No, that sounded pretty good. We are currently working through the

frequently asked questions that area.


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Michelle Mills: OK. So we encourage folks to check back. Hopefully, we were hoping that it would be posted by today before the HIMSS Conference next week but we have to get, legal questions like this clear to a number of folks so it looks like it’ll be next week when it’s posted so just check back.

Diane Maupai: Hi, this is Diane; I’m going to ask everyone a favor. We have a lot of people

waiting to ask questions so if you could limit yourself to your one most important question. At the end of the presentation today I’ll give you a number you can call and direct any other questions you might have.Thank you very much.

Operator: Your next question comes from the line of Ferdinand Velasco, your line is

open. Ferdinand Velasco: Thanks, good afternoon. Ferdinand Velasco from Texas Health

Resources, a question about the step after registration for eligible hospital, currently the person who controls the NPPES web login is a senior vice president of finance so he’s the one that’s done the registration but for the next step which is the attestation for Meaningful Use, would it be he the person or is there some way that he can designate somebody else to perform the attestation for Meaningful Use?

Michelle Mills: Yes, that’s a really great question and Paige and Nancy are on the line, she

should definitely correct me if I’m wrong about this but the processes to go in and request the change in your Authorizing Official or your AO as its documented in some places in order to have someone else make that change your current Authorizing Official, which sounds like is going to be your senior VP is we need to authorize the addition of a new AO. Paige or Nancy, do you want to add anything to that?

Paige Falk: Yes, this is Paige; the only thing that I would say is that actually you don’t

have to request a new Authorized Official you can have the person working on behalf of the hospital request access as an end user. In that way the Authorized Official should remain and that first – that Authorized Official would provide approval for the end user to come in and attest on behalf of the hospital.


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Ferdinand Velasco: Excellent, thank you very much and it would be helpful to share that via frequently asked question on the website, thanks.

Michelle Mills: Thank you very much for making that suggestion. We are in the process of

getting more detailed information put together about some of these registration nuances like I mentioned in the slides, the number of different systems where we’re pulling information and in order to expedite this whole registration and attestation process so as a result there are a couple of little perks for some providers and we are looking at getting more information out about that so thank you.

Operator: Your next question comes from the line of Raymond Kreichelt. Raymond Kreichelt: This is Ray Kreichelt I’m with Nemours in Jacksonville, Florida, we’re a

pediatric organization. My question is to do with whether or not we can receive incentive payments this he first year based on adoption, implementation and upgrade or whether we must show a Meaningful Use. We had certified Electronic Health Records in place before 2011 so in essence we’re not going to be putting them in place in 2011 but it would be a lot easier for us this first year to apply under the AIU as opposed to the Meaningful Use.

Michelle Mills: Great. So thank you, that’s a really great question and it allows me to touch

on two things. One is that in order to participate in this program for Medicaid you don’t have to Meaningfully Use in your first year; you can adopt, implement or upgrade certified EHR technology. The second issue is that the certification program started in the fall of 2010 so if you had something that had like an older CCHIT certification or some other vendor certification prior to that time that is not considered certified in order to meet Meaningful Use for this program. Everyone does have to go to the CHPL or the Certified Health IT Products List in order to get a certification number to make sure that the product is certified in order to meet Meaningful Use. The reason we’re doing that to show some background is that there are a lot of products out there that were certified prior to these new standards and requirements that they don’t talk to each other. They don’t meaningfully exchange health information or do a number of the other activities required to Meaningful Use in this program so we have new and different certification program and folks


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you have to get –- it’s not even the providers it’s the vendors that have to get recertified. I again, just want to check with Larry Clark and see if I missed anything.

Raymond Kritchov: Can I just follow on just if I heard you correctly you’re saying that we can

do it under AIU as opposed to Meaningful Use this year. Michelle Mills: So long as you have a number from the CHPL site. I just want to make sure

when you said you got certified prior to 2011 that it was in fact under the new program and not an old featured certification.

Raymond Kritchov: Well, I guess that’s my questions if we were certified in a new program in

2010 can we still go under AIU in 2011. Larry Clark: Yes, but what Michelle is saying is go to the CHPL and pick your products

from the list there then submit them to the cart. When you submit them to the cart you will then see whether they are in fact certified under our program now and you’ll receive a number and that number will tell you whether a product is certified for this program.

Michelle Mills: So if everything is fine and you’re certified under the current program

requirements yes you can absolutely – even if it’s just placed at the end of 2010 you are qualified in the program for 2011 as long as you meet the other requirements.

Raymond Kritchov: Great, that makes it a lot easier. Michelle Mills: OK. Raymond Kritchov: Thank you. Operator: Your next question comes from the line of Ron Nelson, your line is open. Ron Nelson: This is Ron Nelson with the National Association of Rural Health Clinics.

We have run into an issue where, for example, one State has informed one of the Rural Health Clinics that is PA owned and lead that because the State of North Carolina does not credential separately for Medicaid payment, the PA they will not make any incentive payments and unfortunately that could be the


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case in many, many States that require the billing to flow under a physician’s name, so the question is how is that dealt with.

Michelle Mills: So, Ron that’s a great question; since it does impact so few providers what I’d

like to do is handle that outside of this call with you in the States that are impacted. If you want to call the EHR Incentive phone number, which is 1-888-734-6433, they will be able to help you there or it will eventually get routed back to me or also I worked with Bill Finnerfrock from your organization I believe and Bill knows how to get hold of me as well.

Ron Nelson: OK, thank you. Operator: Your next question comes from the line of Michael Sutter, your line is open. Michael Sutter: This is Mike Sutter from Coral Hospital. AHIMA put an alert out yesterday

that indicated CMS was going to announce or has announced that for EP registration it was acceptable as an EP designated and authorized individual from their practice to perform their registration and attestation for them, which appeared to be contrary to what I thought I heard during the presentation.

Michelle Mills: Great, so the information they put out is also on our website I believe and

what it’s describing is that we are in the process of developing that technology that we need in order to have somebody come in and authorize somebody else to register or attest on their behalf that functionality is not yet available for eligible professionals, we do expect it to be available this spring.

Michael Sutter: OK, so if we wanted to utilize that function then we should not register EPs

now but if we would register them is there a way to retrospectively go back and designate an authorized individual?

Michelle Mills: No, it’s not retrospective it would be going forward. Michael Sutter: OK, good, all right thank you. Operator: Your next question comes from the line of Cathy Selig, your line is open. Cathy Selig: Hello. We have a free-standing lab that has interconnectivity with the

hospital, we do not share the same EHR, the pathologist eligible to these


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incentive payments. I haven’t heard a pathologist mention who are not hospital-based?

Michelle Mills: So pathologists that are not hospital-based are just regular physicians so they

would qualify for both programs. All specialty types that fall under the MD or DO designation so long as they’re, you know, licensed to practice in their State and so are eligible. Please note the hospital-based definition—it’s not based on location, but rather billing through the place of service.

Cathy Selig: Thank you very much. Operator: Your next question comes from the line of John Webble, your line is now

open. John Webble: Does the State qualify as a provider? Michelle Mills: OK, there we go great. So John was asking if a State organization can be

considered a provider for this program and the answer to that is no. The only providers under Medicaid are the five eligible professional types and then the hospitals the two types either acute care or Children’s hospital. The FQHC, RHC, group practices and so on none of those entities are eligible themselves to receive an incentive. Eligible professionals at those locations may receive an incentive and they may reassign payments to those locations. Next question.

Operator: Your next question comes from the line of Tony Murray, your line is open. Tony Murray: Yes, I had a question regarding the Medicaid. There are so many forms of

Medicaid, is there a particular Medicaid that are qualifying under the incentives.

Michelle Mills: What State are you calling from? Tony Murray: Florida.


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Michelle Mills: Florida? So, Florida has a combination of Medicaid and – their Medicaid program would be managed care and Fee-For-Service – I think in different programs for those different methodologies…

Operator: Are you there? Michelle Mills: Yes. While a State like – many States have that same situation so Medicaid

has a programs or laws for beneficiaries so there might be special programs for the aged, blind, disabled or dually eligible Medicare and Medicaid beneficiaries for children, pregnant women, foster care kids and so on. The State looks for opportunities to provide the best care and sometimes that means segmenting the Medicaid population like that with different pairs or different programs. So, as long as the service or the encounter was paid for by Medicaid or 1115 Demonstration Waiver it is authorized under Medicaid; the service then recounts for the patient volume. Your State should be able to help you designate, if it’s Medicaid versus another payer source.

Tony Murray: OK. Yes, they’re all – for some reason they all fall under the Medicaid but

there may be like healthy kids or what not and I think that probably falls under that but do you have a number or should we just call the Medicaid.

Michelle Mills: I would like –I think Florida has a website so I would go to the web page first

and see if they have some information there and that there should be some contact information a well.

Tony Murray: All right. What’s the website? Michelle Mills: I don’t have Florida’s website with me now but if you Google for it actually

you can find it. Tony Murray: And you’re talking about for the Medicaid right. Michelle Mills: I’m talking about the Medicaid EHR, Incentive Program. Tony Murray: OK, no problem. Thank you so much.


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Michelle Mills: You’re welcome. Sorry, I would also add to that last person that the – on our CMS Website under the information for Medicaid providers we also have a link that provides information to each of the State’s websites as well.

Diane Maupai: And that’s on the Medicaid State Information Page; there’s a tab on the left

you can select. Question and Answer Session continued Operator: Your next question comes from the line of Jan Onik, your line is open. Jan Onik: Thank you. Jan Onik, Pike Medical Clinic in Missouri; the purchase versus a

lease of an her, does that affect payment? Michelle Mills: Wow, we’re getting lots of Missouri callers today, good turnout there. So Jan

it sounds like you’re asking in terms of adopting, implementing, upgrading certified EHR technology, what we mean by those different things. So, we do have some information on our website that kind of takes a (inaudible) but what we’re really looking for is that someone is legally liable to make payment for that certified EHR technology.

Jan Onik: If we lease the technology versus buying it does it affect your status? Michelle Mills: No. So it isn’t a purchase, per se; you could be under a purchase order,

contract, a lease whatever it is any of those things are fine. Jan Onik: Thank you. Operator: Your next question comes from the line of Teresa Sperling, your line is open. Teresa Sperling: University of Missouri. I have a quick question about the EP registration

where it says that the information will come from the PECOS system for Medicare and it only has according to there’s like one Tax ID number where the provider is linked to more than one Tax ID number through PECOS.

Michelle Mills: So, that’s a great question. I don’t want to get into that here today because it’s

going to confuse folks that were calling in just for Medicaid EHR Incentive Program requirement.


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Teresa Sperling: OK. Michelle Mills: We touched on Medicare a little bit just in order to illustrate the differences in

the two programs but we do expect to have a Medicare provider call here in the next few weeks.

Teresa Sperling: OK, I will look out for that then. Michelle Mills: Great, thank you. Teresa Sperling: Thank you. Operator: Your next question comes from the line of Coney Reson, your line is open. Coney Reson: I’m Coney Reson I’m calling from North Mississippi Medical Clinics. We

currently have an EHR but it’s not a certified version; my question is should we register now even if we may not have the certified EHR for 2012 so I guess the question is, do you have to register and attest to the certified version in the same year?

Michelle Mills: No you don’t, the benefit to registering now is that you have it taken care of

so, you know, if you’re like – some folks – and you procrastinate and you won’t take care of it until later then you – it’s done. The second part of that though is that when you do register in Mississippi when the State receives that bio they’re going to say well we can’t pay you until we have that certified EHR technology number anyway. So that could be this year, it could be next year or you can just wait to register until you have that information, it’s up to you. Also, you can make sure there is nothing holding up your registration and you would know you’re good to go on that end.

Coney Reson: Thank you. Operator: Your next question comes from the line of Orest Dubynsky, your line is open. Orest Dubynsky: Thank you. It’s Dubynsky and I’m a pediatrician in Greeley, Colorado. I do

have actually 43 percent of my patient population in the Medicaid program. At the beginning when you gave the information about the websites and


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everything, I apologize I couldn’t scribble fast enough and I did not get an e-mail with the slides, I just wanted to make sure that I could get a copy of those so that I could then follow up on the things I need to do.

Diane Maupai: I am hoping that will be posted on our website later today. So just check back

and see if you have a copy of what you got when you registered your confirmation or you can look – let me put it this way, look on the CMS Website on the Spotlight of Upcoming Events Page and I’m hoping it will be posted later today or tomorrow morning.

Orest Dubynsky: OK. Michelle Mills: I’m sorry, you have another question. Orest Dubynsky: No, I just wanted to make sure I got the slides so that I can do what I need. Michelle Mills: Well, thank you for your high volume of Medicaid participation. Orest Dubynsky: Thank you, bye. Operator: Your next question comes from the line of Tracey Holmes, your line is open. Tracey Holmes: Hi, this is Tracey Holmes with Inlet Cardiopulmonary Associates. I believe

you answered my question a few questions ago. Did you say that dual eligible patients, patients who have Medicare and Medicaid, can qualify for the Medicaid incentive payment as long as there’s payment made?

Michelle Mills: So just to be clear to you, incentive payments are going to eligible

professionals for either Medicare or Medicaid. The Medicaid program has a requirement that you serve a certain number of Medicaid or a certain volume threshold for Medicaid patients in order to qualify. Dually eligible patients therefore the payer sources both Medicare and Medicaid they would be counted in the numerator when you’re making a Medicaid patient volume determination but the payments themselves are not in any way based on the patients otherwise the eligibility program is.

Tracey Holmes: OK.


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Michelle Mills: Yes. Tracey Holmes: OK, thank you. Operator: Your next question comes from the line of Rodney Peele, your line is open. Rodney Peele: This is Rodney Peele from the American Optometric Association and I just

wanted to confirm so there’s no confusion for people on the call that optometrists are eligible for the Medicare incentives and that optometrists may also be eligible for the Medicaid incentives if their State takes the actions described in the Final Rule than the other CMS guidance?

Michelle Mills: So we have some very specific requirements around how optometrist might

qualify for the Medicaid incentives, we don’t expect this to impact that many optometrists; however, we do have a frequently asked question on our website about that. CMS is working with States who are interested in trying to expand that eligibility. There could be for many States other program consequences in order to expand the eligibility; since this doesn’t impact that many folks that would be on this call, I recommend that folks check the CMS Website we have an FAQ that was recently updated about this and then Rodney knows how to get in touch with me and so if there are further questions we can address it that way.

Rodney Peele: Thanks, very much Michelle. Operator: Your next question comes from the line of James Davis, your line is open. James Davis: This is James Davis from Pines Health Services in Maine. We’re a Federally

Qualified Health Center. My question has to do with how can we go about executing the assignment for all of our physicians in mid levels who are employed by the practice so that their incentive payments would come through the practice which is the entity incurring the expense rather than ...

Michelle Mills: Sure, James that’s a great question and I definitely expected someone to ask

that question on this call. So this would apply to not only FQHCs but group practices or other clinic locations where the clinic themselves shelled out the


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cash to buy the EHR right, so they feel like they should recoup the cost associated with that – for them should be offset by these incentives. This program was established not to pay for the EHRs but rather to incentivize Meaningful Use at the provider level. So we said, hey providers we’re going to give you some money and you’re going to adopt a Meaningful Use this EHR technology. So sometimes, these providers didn’t pay for it themselves but with the clinic or that your practice has at their disposal is the EHR certification information. The person cannot qualify for this program to receive an incentive unless they have certain information from that clinic or their practice. They’ll probably also need information from you about their patient volume and so on as well. The program - it’s voluntary for a provider to reassign payment but we expect that employment contracts will get renegotiated.

My mom is a nurse practitioner, I know that at her location they’ve talked

about saying, you know, you need to turn your incentive over to us as a condition of your employment contract you need to turn that incentive back over to the group practice but if you are a meaningful user we’ll give you a bonus at the end of the year as well. So we’re expecting to see things happen like that at the clinics and group practices so that the clinics can recoup some of the costs that they shelled out in order to get the EHR, but again since the Meaningful Use is to take place at the provider level this is sort of a team effort here.

Diane Maupai: This is Diane, I just got the word from the better late than never department

that the slides are now posted on the CMS Website on the Spotlight and Upcoming Events Page at the bottom of the page. So we can take the next question.

Operator: Your next question comes from the line of Ron Swartz, your line is open. Ron Swartz: Good afternoon, my name is Ron Swartz and I am with the Child Health

Administrative Services in Cincinnati and we serve as IT technology partner to community docs as it relates with Sunside Children’s Hospital. My question specifically is, as it relates to Medicaid incentive payments or donation made


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to an EP by an organization as allowed by Stark effective providers opportunity to take advantage of both benefits.

Michelle Mills: So I’m sorry, you’re working with the hospital that you’re asking about

eligible professional requirements specifically, just trying to make sure we understand.

Ron Swartz: Well, the hospital is offering a donation as well by Stark in that – my question

is if an eligible professional has the prerequisite as it relates to pediatricians 20 percent minimum. If it has the 20 percent minimum and meets the other requirements for the Medicaid Incentive Program will they be pre-empted from qualifying for that incentive benefit if they have accepted a Stark donation.

Michelle Mills: So I’m not comfortable answering this question without some more

information so what I recommend doing is, asking you to call that number for our helpdesk which I guess is 1-888-734-6433 and we can make sure that your question gets routed to the appropriate folks here for an answer.

Ron Swartz: Great, thank you very much. Michelle Mills: You bet. Operator: Your next question comes from the line of Kim Clark, your line is open. Kim Clark: I’m sorry; my question was just answered so I won’t have to take up

anybody’s time. Michelle Mills: Thank you. Operator: Your next question comes from the line of David Gardner, your line is open. David Gardner: Hello, I work for Alexandria Neighborhood Health Services in Alexandria,

Virginia like Mr. Davis’ facility we’re an FQHC. Is there a registration component for our Authorized Official at the CMS Website or is that kind of pulled from PECOS or somewhere else before eligible professionals can apply for the incentive payment.


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Michelle Mills: So the Authorizing Official for the FQHC is a different entity than the eligible professionals being able to register and attest for the program so just to clarify the functionality that would allow someone like one of your administrative staff for example to be an Authorized Official for the eligible professionals, we don’t have that functionality yet; we’re expecting that to be ready in the spring so right now eligible professionals do need, if they were to register today, which they don’t need to do because Virginia’s program hasn’t launched but if they were to register today they would need to go ahead and do that themselves. Since Virginia plans on launching their program after the spring that capacity should be available for them to go in and designate one of your administrative staff as their Authorizing Official for this program. I just want to check in with Paige to see if I answered that correctly.

Paige Falk: Yes, you did. David Gardner: My question is just a little bit different though. Is our FQHC like already

registered and ready to go at the CMS level just by virtue of our Medicare and Medicaid participation or is there a step for someone from the FQHC has to kind of turn the switch on as it were like at the CMS Website in order for any providers working at the FQHC.

Michelle Mills: Right. Your FQHCs are not eligible themselves as entities to receive

incentive payments but it sounds like you’re asking if there is some step that needs to take place in order for the eligible professionals to designate you as their Tax ID number for payment, is that correct?

David Gardner: Not at all. I think your answering my question by the lack of the answer I

guess an eligible professional can right now register on CMS and there’s nothing that FQHC facility needs to do.

Michelle Mills: That’s right; the eligible professional needs to have their web user account for

NPPES, their NPI web user account, in order to initiate their registration. David Gardner: Got it. I think my confusion was – I think we have led to believe that the

Authorized Official had to register in PECOS before our eligible providers could register in PECOS and maybe I could be wrong there but I just


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wondered if there was like a corresponding kind of registration step at the CMS level, is that ...

Michelle Mills: There are different activities that need to take place for hospitals that doesn’t

apply because they are eligible for the incentives but that does not apply to FQHCs.

David Gardner: Got it, thank you. Operator: Your next question comes from the line of Sandy Wolfe, your line is open. Sandy Wolfe: Hi, we are in the process of registering our facility and when we went out to

try and register we didn’t have that PECOS account for the website so we had to request an NPPES account. When we tried to select subsection(d) Providers it would not allow us, it said there was – it did not match the PECOS enrollment form even though clearly the CCN number was the appropriate provider number for an acute care facility. I don’t know who to contact to get that resolved.

Michelle Mills: Yes. Sandy, that’s a good question. We have a small subset of hospitals that

are falling into that same bucket. We have guidance on our CMS Website about how to proceed or you can also call the help desk phone number that we’ve given out here on this call and it’s included in the last slide in order to get help as well, but I recommend going back and checking through the steps that we have in the guidance on our website. I don’t remember which page that’s on, at the top of my head I think it’s on the hospital page but I’m not positive. You can also contact your State for more information on that too. We have a very specific procedure in place about how they get that handled.

Sandy Wolfe: Thank you. Operator: Your next question comes from the line of Karen Armstrong, your line is

open. Karen Armstrong: Hi, my name is Karen Armstrong, I’m a Certified nurse midwife in Oregon

and I have a question about where a group practice we provide group care to our patients although we go under the name of providers as the delivery so


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does each provider in our practice have to individually register and then can they assign the payments to go to the Tax ID number of the practice, which is how our current claims are paid and is the Medicaid program then a set amount or is it a percentage of what is billed?

Michelle Mills: So, two questions, the first one is the easy one. Medicaid is a set amount and

the first year of 21,250; it’s 8500 in the five subsequent years for a total of 63,750 in the Medicaid program. The second question about group practices also applies to clinic. We have a rule for those of you who like to look at Federal regulations, which is I’m sure is a whopping number out there but a rule at §495.310(h) that talks about how to apply a group of clinics patient volume as a proxy for the individual. So we wanted to make an administrative flexibility here for clinics or group practices like yours that probably don’t – since a Certified nurse midwife practices of course the patient would probably see most of you and so who had an encounter with whom and when is harder to track and it’s very similar in a lot of primary care practices or FQHCs not like other OB practices and so on.

So what we said was that if you look at the whole clinic or groups practice the

patient volume for that practice that could be applied towards any of the eligible professionals in that clinic or group practice under certain restrictions. So it needs to be appropriate for those providers. For example, we have an all in or all out provision also so that means that you can’t peel off certain providers, it’s either the clinic’s practice volume or nothing but I encourage folks to check that out. We also have FAQs on our website that address this issue too.

Karen Armstrong: OK, we easily qualify; we have – 50 percent of our population is under

Medicaid. Michelle Mills: Great, so then all of your Certified nurse midwives should qualify then as

well. Karen Armstrong: OK thank you. Operator: Your next question comes from the line of Caroline Roberts, your line is open.


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Caroline Roberts: Hi, this is Caroline Roberts and I work for Basic Medical Practices in Massachusetts and my question is this, if we’re not sure which program to enroll in Medicaid, EHR or Medicare EHR if we enroll in both can we – once we run the numbers to see if we qualify or, you know, which one would be more beneficial; can we disenroll and not hurt ourselves, disenroll in the program we don’t want.

Michelle Mills: So, the hospitals could register for both Medicare and Medicaid, eligible

professionals cannot. Our system will not let you register for both, you have to pick one or the other, you can go back in and change it any time before payment and if you can go back and forth and change it three or four times before payment, but you do have to select one program or the other. Additionally, I wanted to highlight on our CMS Website we have an Eligibility Wizards that will walk providers through – at a 30,000 per level, which program you’re more suited for.

So, if you qualify for the Medicaid program you should participate in the

Medicaid program. You get quite a bit more money over the course of the program than you do in Medicare so the benefit is really given the financial you’ll get an extra $20,000 over the course of the program in order to participate so I would take a look at that Eligibility Wizard also to see if that can help you determine your qualification and your Massachusetts organization is working on this program, it’s fantastic, they have a lot of good materials out there; I’d check their website and work with the RACs if you’d like.

Diane Maupai: Hi, this is Diane, I’m sorry we’re out of time for questions today. I know

there are a lot of you in the queue and I’m sorry we couldn’t get to all of you. So I’d like to take a minute and tell you about some other resources that are available and if you have more questions the State and the EHR information center are available to help.

Again, there’s information about the information center on our webpage, it’s

on the Registration and Attestation page of www.cms.gov/EHRIncentivePrograms and I also want to let you know that there’s a new way to stay informed about the EHR incentive program. CMS

http://www.cms.gov/EHRIncentivePrograms�


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has created a new listserv specifically for these programs. They’ll provide e-mail updates on things like registration and attestation, payments, deadlines and Qs and As.

So you can sign up for this listserv on the CMS EHR Incentive Program

Listserv page on the CMS Website. An audio and a written transcript of this call are going to be made available on the Spotlight and Upcoming Events Page of the CMS Website in a couple of weeks. I’d like to thank Michelle and all of you for joining us today and have a great holiday weekend.

Male: Thank you. Operator: This concludes today’s conference call, you may now disconnect.

END

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Medicaid EHR Incentive Program for Eligible Professionals

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