STATE OF INDIANA Family and Social Services Administration, Office of Medicaid Policy and Planning

Transcription

1 STATE OF INDIANA Family and Social Services Administration, Office of Medicaid Policy and Planning State Medicaid Health Information Technology Plan (SMHP) Annual Update August 2016

2 Version Date Revision History Author(s) Number 1.0 December 2010 Indiana HIT SMHP first draft submitted to OMPP for review Fox Systems 1.06 January 2011 Indiana HIT SMHP submitted to CMS Jared Linder 1.09 March 2011 Indiana HIT SMHP resubmitted to CMS based on feedback Jared Linder 1.10 April 2011 Indiana HIT SMHP resubmitted to CMS with required changes in accordance with CMS April 4, 2011 Letter and Enclosures A, B, and C sent to Pat Casanova, Indiana Medicaid Director. Pat Casanova received CMS approval of the IN HIT SMHP V1.10 by Rick Freidman via dated April 26, Jared Linder, Pat Casanova 1.11 March 2012 Indiana HIT SMHP developed as an annual update to be submitted to CMS; applied the State Medicaid HIT Plan (SMHP) Template to the Indiana 2012 Annual Update of the SMHP; and Applied the FSSA HIT Coordinator and HIT Project Manager changes to reflect document as the final version. 2.0 March 2013 and May 2013 Numerous minor updates across the entire document. Areas which changed most significantly include: - Update on Medicaid-related HIT activities (see section 1.2) - Update on as-is HIT landscape including adoption of e- prescribing and electronic transmission of continuity of care information (see sections 1.3; 2.1; 2.4) - Update on status of statewide HIE initiatives/activities (see section 2.6; 2.7; 2.9; 6.3) - Update on status of related initiatives such as the projects funded by Beacon grant awards and developments in statewide broadband-class communications deployment (see sections 2.5.3; 2.5.4) - Reaffirmation of Indiana s to-be vision and roadmap for HIT and HIE in support of its medical assistance programs (Indiana Health Care Programs) (see sections 3.2; 6) - Update on other Medicaid IT and IT-related initiatives such as MMIS, enterprise data warehouse and PBM with enhanced IT capabilities (see sections 2.1.3; 4.4; 6.4) - Update on EHR incentive program s administrative structure, system capabilities (the latter focused on MAPIR) and ongoing provider communication and outreach efforts (see sections 1.1; 4.6; ; ; 4.14) - Update on the EHR incentive program s Audit Strategy (also refer to the Audit Plan submitted to CMS) - Per feedback from CMS received in May 2013: added to sections 4.8, 4.12 and 4.13 and provided a completed Amie Redmon, Jared Linder, Pat Casanova Health Management Associates, Carenza Love Page 2 of 81

3 Version Number Date Revision History Author(s) 2013 State Medicaid Changes Checklist as an addendum 3.0 May June 2014 Indiana HIT SMHP Final update submitted to CMS Numerous minor updates across the entire document. Areas which changed most significantly include: - Update on summary of activities conducted during Year 3, and key program statistics update (see section 1.2) - Update on transition of state level designated entity HIT/HIE leadership from IHIT to FSSA (see sections 2.1) - Update on electronic information exchange statistics (see section 2.4) - Removed entire section on IHIT governance (formerly section 3.1.1) - Update on executive leadership description (see section 3.1.2) - Update on timeline of key state Medicaid HIE/HIT initiatives (see sections 3.2 and 6.1) - Update on requirements for pre-payment review of attestation verification (see 4.12) - Removed section on coordination with IHIT (formerly section 4.20) - Updates on the State s Audit Strategy (see sections 5.0, 5.4, 5.5) Indiana HIT SMHP Final update submitted to CMS Numerous minor updates across the entire document. Areas which changed most significantly include: - Update most SMHP-U and APD-U submission and approval dates (see section 1.1) - Summary of HIT activities conducted during Year 4 and key program statistics update (see section 1.2) Carenza Love Carenza Love MITA self- assessment completion update (see section 2.12) 4.1 April 2016 Addendum for Modifications to Meaningful Use in Myers and Stauffer, LC 2017 Final Rule - Table for changes to Eligible Professional (EP) Meaningful Use objectives and reporting periods - Table for changes to Eligible Hospital (EH) Meaningful Use objectives and reporting periods 5.0 August 2016 Full rewrite and/or update to all sections and subsections Myers and Stauffer, LC Page 3 of 81

4 Version Number Date Revision History Author(s) Section 6: The State s HIT Roadmap added as required by CMS in 2015 Page 4 of 81

5 Table of Contents A. Introduction and Overview A.1 EHR Incentive Program Overview A.2 Summary of HIT Activities to date in Year A.3 Summary of Indiana s HIT Future B. Indiana s As Is HIT Landscape B.1 Current HIT Environment Overview B.2 HIT Activities Supporting Medicaid B.3 OMPP Quality Monitoring and Improvement B.4 Electronic Information Exchange B.5 Electronic Public Health Reporting B.6 Statewide HIE Networks B.7 Core Interoperability Projects B.8 Current HIE Architecture/Structure B.9 Governance for State Health Information Exchange B.10 Veterans Administration and Indian Health Services Providers B.11 Medicaid Information Technology Architecture (MITA) B.12 MMIS HIT/HIE Environment B.13 Summary of Medicaid Environmental As Is E-scan C. Indiana s To Be HIT Landscape C.1 Public-Private Stakeholder Cooperation C.2 Vision for HIT Environment C.3 Public Health Health Information Technology Strategy D. Activities Necessary to Administer and Oversee the EHR Incentive Program D.1 Concept of Operation and Administration D.2 Audit Work Group D.3 Technology Work Group D.4 Clinical Quality Work Group D.5 Provider Communications D.6 Recent Changes in State Laws and Regulations D.7 Policy Changes D.8 HIE/HIT Activities across State Borders Page 5 of 81

6 D.9 Privacy Regulatory Changes D.10 Provider Contract Changes D.11 Provider Eligibility Determination D.12 Processing Payments to Providers D.13 Provider National Provider Identifier (NPI) D.14 Role of Contractors in Indiana EHR Incentive Program Implementation D.15 Reporting Requirements D.16 Coordination with Medicare to Prevent Duplicate Payments D.17 Incentive Payment Recoupment D.18 Fraud and Abuse Prevention D.19 Provider Appeals D.20 Federal Financial Participation (FFP) D.21 Meaningful Use and Patient Volume Criteria D.22 Dependence upon Federal Initiatives E. The State s Audit Strategy E.1 Category 1 Incentive Payment Audits E.2 Category 2 Administrative Expense Audits E.3 Audit Settings E.4 Audit Methodologies, Standards, Processes, and Procedures E.5 Audit Planning F. The State s HIT Roadmap F.1 Moving from As Is to To Be HIT Landscape F.2 Tactics to Support the Strategy for the HIT Roadmap F.3 MMIS-Related Activities F.4 HIT Objectives for Meaningful Use of Clinical Data Page 6 of 81

7 List of Key Terms and Acronyms The following acronyms are used throughout the document: Acronym ACA ADT AHRQ AIU CAH CCD CCN CEHRT CHC CHIP CHIRP CHPL CIO CMO CMS CPOE CQM D4D DA DDRS DFR DMHA DUA ED EDW EH EHR ELR EP ESB ESSENCE FA FCC FFP FFS FFY FQHC FSSA Definition Affordable Care Act Admit, Discharge, Transfer Agency for Healthcare Research and Quality Adopt, Implement or Upgrade Critical Access Hospital Continuity of Care Document CMS Certification Number Certified Electronic Health Record Technology Community Health Center Children's Health Insurance Program Children and Hoosier Immunization Registry Program ONC Certified EHR Health IT Product List Chief Information Officer Care Management Organization Centers for Medicare & Medicaid Services Computerized Physician Order Entry Clinical Quality Measure DOCS4DOCS Division of Aging Division of Disability and Rehabilitative Services Division of Family Resources Division of Mental Health and Addiction Data Use Agreement Emergency Department Enterprise Data Warehouse Eligible Hospital Electronic Health Record Electronic Laboratory Reporting Eligible Professional Enterprise Service Bus Electronic Surveillance System for the Early Notification of Community-based Epidemics Fiscal Authority Federal Communications Commission Federal Financial Participation Fee-for-Service Federal Fiscal Year Federally Qualified Health Center Indiana Family and Social Services Administration Page 7 of 81

8 Acronym GUI HEDIS HHS HIE HIO HIP HIPAA HISP HIT HITECH HP IAC IAPD IAPD-U IHA IHCP IHIC IHIE IHIT IHS IIS INPC IPHCA IRS ISDH ITN LEIE MAPIR MCO MED MHIN MITA MMIS MOU MSLC MTF MU NCD NCQA NPI NPPES Definition Graphic User Interfaces Healthcare Effectiveness Data and Information Set Health and Human Services Health Information Exchange Health Information Organization Healthy Indiana Plan Health Insurance Portability and Accountability Act Health Information Service Provider Health Information Technology Health Information Technology for Economic and Clinical Health Act Hewlett Packard Indiana Administrative Code Implementation Advance Planning Document Implementation Advance Planning Document Update Indiana Hospital Association Indiana Health Care Programs Indiana Health Informatics Corporation Indiana Health Information Exchange Indiana Health Information Technology, Inc. Indian Health Services Immunization Information System Indiana Network for Patient Care Indiana Primary Health Care Association Internal Revenue Service Indiana State Department of Health Indiana Telehealth Network List of Excluded Individuals Entities Medical Assistance Provider Incentive Repository Managed Care Organization Medicare Exclusion Database Michiana Health Information Network Medicaid Information Technology Architecture Medicaid Management Information System Memorandum of Understanding Myers and Stauffer LC Camp Atterbury Medical Treatment Facility Meaningful Use Notifiable Conditions Detector National Committee for Quality Assurance National Provider Identifier National Plan and Provider Enumeration System Page 8 of 81

9 Acronym OMPP ONC PAPD PCCM PECOS PHA PHA PHESS PTN PY R&A REC RHC SDE SHIECAP SMHP SOA SSA SUR TA TCPI TIN VLER VXU Definition Office of Medicaid Policy and Planning The Office of the National Coordinator Planning Advance Planning Document Primary Care Case Management Provider Enrollment, Chain and Ownership System Purdue Healthcare Advisors Public Health Authority Public Health Emergency Surveillance System Practice Transformation Network Program Year Medicare & Medicaid EHR Incentive Program Registration & Attestation System Regional Extension Center Rural Health Center State Designated Entity Health Information Exchange Strategic and Operational Plan State Medicaid Health Information Technology Plan Service Oriented Architecture Social Security Administration Surveillance Utilization and Review Technical Assistance Transforming Clinical Practice Initiative Taxpayer Identification Number Virtual Lifetime Electronic Record Unsolicited Vaccination Record Update Page 9 of 81

10 A. Introduction and Overview The Indiana Family and Social Services Administration (FSSA) in conjunction with The Office of Medicaid Policy and Planning (OMPP) is the State entity responsible for administering the Indiana Medicaid program with approximately 1.46 million enrollees 1. FSSA is committed to improving the quality of care for Medicaid beneficiaries in the State and the health status of this population and strongly believes that health information technology (HIT) can have a significant impact on health care quality, outcomes, and health status. Thus, FSSA is committed to continuing to work with health care providers to better serve their patients through data sharing of electronic health information and meaningful use of HIT. The implementation of the Medicaid Electronic Health Record (EHR) Incentive Payment Program initiative (hereafter referred to as the EHR Incentive Program or Program ) is a major cornerstone towards improving provider access to, and use of, electronic health information that should lead to improved health outcomes and status for Medicaid members. Since May 2, 2011, the State of Indiana has been operating its EHR Incentive Program per 42 CFR Parts 412, 413, 422, 495, et al. Funding for the Program is provided at a 90% match by the Centers for Medicare & Medicaid Services (CMS), while the State of Indiana provides the additional 10% matching funds for program administration activities. In order to participate in the EHR Incentive Program, a State Medicaid Health Information Technology Plan (SMHP) must be submitted and approved by CMS. Moreover, a Medicaid HIT Implementation Advance Planning Document (I-APD) must be submitted by the State and approved by CMS before federal funding can be accessed for program administration and incentive payments to eligible professionals (EPs), eligible hospitals (EHs) and Critical Access Hospitals (CAHs). The State s first SMHP and Medicaid HIT I-APD was approved by CMS in April 2011 and an update (IAPD-U) was submitted in November 2014 and approved in March The State submitted and CMS approved an SMHP addendum for the Modifications to Meaningful Use (MU) in final rule in March Indiana developed the requirements needed to build the operations and IT infrastructure for operating the Program and while the IT infrastructure is substantially in place, the operations infrastructure continues to evolve particularly in response to the requirements in the Modifications to Meaningful Use in final rule published in October In 2010, the Governor of Indiana established Indiana Health Information Technology, Inc. (IHIT) as the state designated entity (SDE) to build on the established work of the four successful private sector health information organizations (HIOs) and named a HIT Coordinator to lead this effort. The four HIOs include: HealthBridge, HealthLINC, Indiana Health Information Exchange (IHIE) partnered with the Regenstrief Institute, and Michiana Health Information Network (MHIN). Since health information exchange (HIE) is a critical enabler of EHR meaningful use, the State incorporated many elements of the HIE Strategic and Operational Plan (SHIECAP) into its original SMHP. The original SHIECAP was approved by the Office of the National Coordinator of Health Information Technology (ONC) on January 21, The ONC-funded grant funding for IHIT expired in March 2014, and the State transitioned the oversight role to FSSA for all statewide HIT/HIE related initiatives and continued coordination of the HIT infrastructure. This SMHP update reflects the ongoing effort to ensure that the SMHP and SHIECAP remain aligned. 1 Based on information in statehealthfacts.org (a publication of the Kaiser Family Foundation) Page 10 of 81

11 During the latter part of 2011, Indiana determined a number of critical projects that had to be implemented for the EHR Incentive Program initiatives for Year 2. An IAPD-U was submitted on December 29, 2011 and approved by CMS on January 18, The State submitted the most recent IAPD-U in November 2014, with a supplemental submission on January 8, 2015, and received CMS approval on March 3, 2015, in the continued support of the following key activities: Development and implementation of verification processes of EPs, EHs, and CAHs regarding their efforts to adopt, implement, or upgrade (AIU) Certified Electronic Health Record Technology (CEHRT) and the meaningful use of said technology as a condition of receiving incentive payments; Implementation and ongoing support of the Medical Assistance Provider Incentive Repository (MAPIR) System, a multi-state collaborative effort that funded an EHR Incentive Program administration system that interfaces with Indiana s Medicaid Management Information System (MMIS); Development and implementation of program integrity procedures and related system changes; Development and implementation of the EHR Incentive Program Audit Plan; and Provider outreach, training and education on EHR Incentive Program rules and the meaningful use of CEHRT. A.1 EHR Incentive Program Overview Implementation and meaningful use of CEHRT will improve access to health information for Indiana Medicaid members and providers. Certified EHRs facilitate easier coordination of care for the many providers who may be treating a Medicaid patient and provide patients with more readily accessible information needed to make important decisions about their health care. Indiana Medicaid will have access to clinical and administrative information for children, pregnant women, disabled, and adult populations and will use this information to improve coordination of care and health outcomes for those Hoosiers served. The State of Indiana has adopted the national goals for the EHR Incentive Programs; these include: 1) Enhance care coordination and patient safety; 2) Reduce paperwork and improve efficiencies; 3) Facilitate electronic information sharing across providers, payers, and state lines; and 4) Enable data sharing using state HIEs and the Sequoia Project ehealth Exchange (ehealth Exchange). Achieving these goals will improve health outcomes, facilitate access, simplify care, and reduce costs of healthcare nationwide. In accordance with provisions within the American Recovery and Reinvestment Act (ARRA), OMPP implemented the Indiana Medicaid EHR Incentive Program to provide incentive payments to eligible EPs, EHs, and CAHs. Additionally, OMPP has worked closely with federal and state partners to ensure the Medicaid EHR Incentive Program aligns with the SHIECAP, thereby advancing state-level and national goals for HIE. The incentive payments directed to EPs, EHs, or CAHs are not reimbursement for services rendered by these providers; they are issued to incentivize the adoption, implementation or upgrade of CEHRT and the subsequent meaningful use of CEHRT as defined by CMS. Page 11 of 81

12 OMPP elected to leverage business processes throughout the agency and, where feasible, integrate the Indiana EHR Incentive Program into the standard Medicaid Information Technology Architecture (MITA) business processes and OMPP s day-to-day operations. During the Implementation Phase, OMPP developed state-specific business processes where a MITA business or organizational process was not identified. Examples of these processes include Indiana EHR Incentive Program eligibility, Indiana Health Care Programs (IHCP) member volume, attestation receipt and validation, and provider registration and query to the Medicare & Medicaid EHR Incentive Program Registration & Attestation System (R&A). During 2013 and into 2014, OMPP transitioned the driver for incentive payments in accordance with the MU Stage 2 rule and will transition to the modified Stage 2 ruling in 2015 and As part of the MAPIR multi-state collaborative, all regulation changes for modified MU Stage 2 have been completed by Hewlett Packard and the implementation of the upgrade to MAPIR has commenced. Indiana s most recent MAPIR upgrades include a combination of version 5.6 and 5.7, which was implemented in July Any future regulation changes that affect provider attestations will be handled in the same manner. A.2 Summary of HIT Activities to date in Year 5 Major Program achievements in Year 5 included, but were not limited to: Opening of Program Year (PY) 2015 for EPs, EHs, and CAHs: o PY 2015 opened briefly in 2015 to allow AIU and MU attestations to the Indiana R&A before it was closed due to the Modification to Meaningful Use in final rule. o PY 2015 re-opened on July 11, 2016, for additional AIU and MU attestations incorporating the changes in the Modification final rule published in October Continuation of audit program per the Audit Plan submitted to CMS: o In 2015, the State resumed AIU audits from PY 2014 recipients. o The State has also completed EP MU audits from PY 2013 recipients. From an information systems perspective, the State continued to participate in the MAPIR collaborative. MAPIR continues to supports the Program s administrative requirements for meaningful use-based incentive payments. o Version 5.6 and 5.7 of MAPIR went live in July The following table (next page) shows incentive payment statistics for EPs, EHs and CAHs as of April Page 12 of 81

13 Figure 1: Key EHR Incentive Program Statistics Type Amounts/Totals Eligible Professionals Unique EP Count 2,887 # AIU Payments 2,772 AIU Payment Total $58,451, # MU Payments 2,124 MU Payments Total $19,065, Total EP Payments to Date $77,517, Eligible Hospitals Unique EH/CAH Count 125 # AIU Payments 100 AIU Payment Total $62,346, # MU Payments 199 MU Payments Total $68,093, Total EH/CAH Payments to Date $130,439, GRAND TOTAL $207,957, Based on information from the CMS Combined Medicare and Medicaid Payments by State and Unique Count of Providers by State reports from CMS.gov. In the first three (3) Federal Fiscal Years (FFYs) of the EHR Incentive Payment Program, OMPP estimated that approximately 3,225 EPs and 76 EHs in the state of Indiana would receive $148 million in EHR Incentive Payments covered at 100% federal financial participation (FFP) under ARRA. The EH estimation was exceeded including attestations and payments in early 2015 while outreach efforts continue to include potential EPs in PY 2015 and PY 2016, the last year to attest to AIU and/or join the Medicaid EHR Incentive Program. A.3 Summary of Indiana s HIT Future OMPP recognizes that the Medicaid Program will play a significant role in transforming health care in Indiana and has developed its vision for HIT to address many of the challenges of integration with the HIO networks. Replacement of the MMIS is a priority project for OMPP. The new MMIS, currently planned to be fully in production by the end of 2016, will provide improved functionality including Service Oriented Architecture (SOA), Enterprise Service Bus (ESB), a rules engine, and automated workflow functions that will support HIT/HIE efforts. The focus aimed at obtaining new technology and then leveraging this technology is an integral part of the statewide HIT solution. Implementation of EHRs will improve access to health information for Indiana Medicaid members and providers. EHRs facilitate easier and quicker coordination of care for the many providers who may be treating a Medicaid patient and provide patients with more readily accessible information needed to make important decisions about their health care. Indiana Medicaid will have access to clinical and administrative information for children, pregnant women, disabled, and adult populations and will use this information to improve coordination of care and health outcomes for those Hoosiers served. The State has data use agreements (DUA) in place with two state HIOs including a DUA with IHIE through June 2017 Page 13 of 81

14 and a DUA with MHIN through February In addition, the State has a Memorandum of Understanding (MOU) with the Indiana State Department of Health (ISDH) through June OMPP began making incentive payments for MU in 2013 and continued 2014 and Activities surrounding Modified MU Stage 2 and gathering Clinical Quality Measures (CQMs) are defined in later sections of this SMHP. To support the implementation of the EHR Incentive Program, OMPP instituted three work groups: 1. Audit Work Group 2. Technology Work Group 3. Quality Work Group These work groups were designed to advise the core OMPP team managing the EHR Incentive Program. The scope of their advisory function included but was not limited to: Developing and reviewing existing policies (e.g. Audit, Program Integrity, Clinical Quality Review, and Quality Improvement Measures, etc.); Building EHR Incentive Program-specific policies, procedures, and checklists; Ensuring that desk audits and field audits are conducted in a manner that has a defined criteria for selection; Results presentation and reportable opportunities for improvement; and Management of regulatory or financial infractions. Having completed four (4) successful years for the EHR Incentive Program, OMPP informally dissolved the above mentioned work groups; however, OMPP and FSSA staff meet regularly to discuss audits and works closely with Indiana s third-party auditor, Myers & Stauffer LC. Indiana continues to participate in the HP MAPIR multi-state collaborative and works closely with the MMIS and MITA implementation and management teams. As Indiana s EHR Incentive Program is further refined and improved upon within, and further defined by CMS with tools refined by the ONC, the State will update any changes necessary in regulations, policy, program, and/or processes. In addition to the updated SMHP, the necessary IAPD(s) will also be developed, updated, and submitted to CMS. Advancing Indiana s MITA maturity within each of the current MITA Business Areas will also continue. Following are just some of the initiatives designed to further the State s MITA capability maturity: The new MMIS; A new Enterprise Data Warehouse (EDW); A new Pharmacy Benefits Management (PBM) solution; A series of HIE initiatives including support of eprescribing, exchange of prior authorization data and clinical data exchange; and Design and deployment of an Integrated Eligibility Determination solution for the State s health care programs. Page 14 of 81

15 B. Indiana s As Is HIT Landscape Indiana completed an initial environmental scan (e-scan) in 2010 as part of its initial SMHP plan to establish a baseline for assessing levels of provider EHR adoption and HIE connectivity. The e-scan revealed widespread adoption of industry leading EHR products among providers primarily in urban areas, and interest from rural provider practices and clinics in how the EHR Incentive Program might help them to acquire EHR capacity. At the time of the scan, Indiana was home to four (4) well-established Regional Health Information Organizations (HIOs). The Governor also established the Indiana Health Information Technology, Inc. (IHIT) in 2010 as the state s designated entity for HIE to lead statewide HIE planning and coordination as part of the State HIE Cooperative Agreement Program (SHIECAP). A second e-scan was performed for this current update to the SMHP in May and June 2016 to reassess the overall adoption of CEHRT in Indiana as well as the transition of the SDE to the state. This e-scan expanded from the original e-scan in 2010 and incorporated surveys and interviews with statewide stakeholders not previously surveyed including mental and behavioral health centers, home health providers, long-term care and rehabilitation facilities, and ambulance services. An overview of the 2016 e-scan is included below in Section B.13. B.1 Current HIT Environment Overview Indiana s HIT environment is active with multi-faceted efforts to support provider HIT capacity and foster the sharing of clinical and administrative data to improve health care and support system improvements. The State has taken an active role through its state health agencies and Medicaid program to promote HIT adoption and HIE development, building upon its private health care marketplace. Indiana continues to be home to four wellestablished HIOs, each functioning in different capacities for community partners. In addition to the HIO efforts with their providers, the State continues to work with one of the original Regional Extension Centers (REC). IHIT s former role as the SDE has now transitioned to FSSA under its Healthcare Strategies and Technologies division and actively participates in the Indiana Hospital Association s (IHA) Council on Information Management and Health Information Exchange Task Force. The State s range of activities will include workgroups, educational forums, targeted activities related to the EHR Incentive Program, and convening activities to foster targeted strategic and tactical plans for expanding HIT and HIE capacity. With leadership from the HIT Coordinator, FSSA is supporting coordination and collaboration among the HIOs and OMPP to foster data sharing among Medicaid providers to promote heath care quality and efficiency. OMPP is contracting with IHIE to aggregate Medicaid claims with medical and pharmacy data in its repository to create a Continuity of Care (CCD) record that can be shared between Medicaid providers. OMPP is also in the planning phase of a similar initiative with the Michiana HIE. E-prescribing is increasing, as evidenced by dramatic increases in the numbers of pharmacies connected to the Allscripts network and e-prescribing rates among providers that have risen exponentially year after year since In line with the State s SHIECAP targets at the end of the first quarter of 2013, the HIOs implemented standardized CCDs via Connect gateways to increase hospital s ability to access clinical care summaries. A consumer engagement strategy is being implemented to expand use of PHR portal and access to immunization records. For Medicaid providers in particular as of early 2016, statistics from Indiana s EHR Incentive Program show that more Page 15 of 81

16 than 2,800 EPs and 125 EHs and CAHs have received at least one incentive payment for the adoption and meaningful use of an EHR. B.2 HIT Activities Supporting Medicaid Within Indiana s executive branch, two agencies administer Medicaid and other health care programs. The Indiana Family and Social Services Administration (FSSA) and its Office of Medicaid Policy and Planning (OMPP) are responsible for the Medicaid program as the designated state agency under the federal Medicaid statute. The Indiana State Department of Health (ISDH) is the public health agency for the state and oversees the local health departments. ISDH is responsible for most of Indiana s health programs. The Executive Board of ISDH, the agency s ultimate authority, and the State Health Commissioner are appointed by the governor. The State Health commissioner is the secretary of the Executive Board and the chief executive of ISDH. By law, the commissioner must be licensed to practice medicine in Indiana. The Secretary of FSSA and the Commissioner of ISDH are required by statute to coordinate related programs, including the Medicaid program. The Secretary of FSSA is accountable for formulating overall policy for family, health, and social services in Indiana, including the resolution of administrative, jurisdictional, or policy conflicts between a division of FSSA and ISDH. By statute, FSSA must advise the Commissioner of ISDH of proposed rules affecting common areas of interest, including Medicaid, and obtain comments from ISDH on the proposed rule. Indiana has multiple health services programs with overlapping constituencies in both FSSA and ISDH. Other divisions in FSSA with Medicaid responsibilities include the Division of Aging (DA), Division of Disability and Rehabilitative Services (DDRS), which administers Medicaid waivers for home-based, long term care for the elderly, disabled and other special populations, and the Division of Family Resources (DFR) which has eligibility determination responsibilities in programs for children, pregnant women and low income families, and the Division of Mental Health and Addiction (DMHA). The Children s Health Policy Board, comprised of the Secretary of FSSA, the State Health Commissioner, the Insurance Commissioner, the State Personnel Director, the Budget Director, the State Superintendent of Public Instruction, and the Director of the Division of Mental Health, directs policy coordination for Indiana s children's health programs, including Children s Health Insurance Program (CHIP). Under the auspices of OMPP, the Hoosier Healthwise Program provides health care services to Indiana s children, low income families and pregnant women. Individuals who enroll in Hoosier Healthwise are eligible for either Medicaid benefits or benefits through the Children s Health Insurance Program (CHIP). The State contracts with Managed Care Organizations (MCO) to provide services to Hoosier Healthwise enrollees through a medical home and a committed provider network throughout the State. Hoosier Care Connect is an enhanced Primary Care Case Management (PCCM) Program provided through OMPP, which contracts with three Care Management Organizations (CMOs). Medicaid HIT related activities are overseen by both FSSA - through the Healthcare Strategies and Technologies Division and ISDH. The HIT Coordinator plays a coordination role between the agencies and with the range of external entities who participate in aspects of the Medicaid program that rely upon sharing electronic health data. Page 16 of 81

17 B.3 OMPP Quality Monitoring and Improvement The overarching mission of the Indiana Office of Medicaid Planning and Policy (OMPP) is to improve the health and quality of Hoosier lives through planning and initiatives concentrating on timely access to health care, cost management, and quality. The Indiana OMPP works to achieve this mission through a strategy that involves data driven decision making, implementation of evidence-based practices, fiscal responsibility, and active engagement with providers, members, health plans, and state and local governments. OMPP supports a multi-faceted program of value-based contracting to serve Indiana s Medicaid and CHIP population, including a strategy for ongoing quality improvement relying upon HIT supported quality reporting and analysis. OMPP began collecting quarterly reports from the MCOs on a variety of quality indicators for preventive health, for children and adolescents, and for pregnant women, and newborns. This increased access to data allowed the OMPP to track and monitor performance on key quality indicators and steer the focus toward improvement activities. Effective January 1, 2008, the Healthy Indiana Plan (HIP) benefits became available through private insurers. The State contracts with three insurance carriers for the HIP program, Anthem, MDWise and Coordinated Care Corporation, to ensure comprehensive and committed health networks across the State are offering a choice of plans to Medicaid enrollees. HIP insurance carriers are required to submit claims/encounter-based, outcomes measures to assess the provision of various screening and prevention measures, as well as immunizations. OMPP also administers the Primary Care Case Management, which contracts with three CMOs, to assist with care coordination, provider relations and member services. Hoosier Care Connect care management services for special populations with disabilities and chronic illnesses. The Hoosier Care Connect contracts include incentive and reporting requirements for addressing conditions amenable to care management, reflecting the unique needs of the disabled and wards/fosters population. OMPP has been able to incrementally raise performance benchmarks, such as well child visits for children 0 to 15 months of age where the percentage of members with six or more visits during the first 15 months of life were measures based on the Healthcare Effectiveness Data and Information Set (HEDIS) W15 using hybrid data. All three MCOs improved year over year from Over time, OMPP has gathered and evaluated clinical quality measures based on paid claims/encounters stored in the MMIS to monitor Medicaid utilization and quality variables. Within the State government, electronic data sharing was instituted between the OMPP and DMHA as well as ISDH, including county level data, to monitor and improve the quality of care for pregnant women, children, and those with serious mental illness. Standardized assessments of persons receiving care at the State s Community Mental Health Centers are received by DMHA and linked to Medicaid claims data in order to better understand total utilization of mental health services. OMPP created the Quality Strategy Committee and holds quarterly meetings where performance data is shared. The Committee s role is to assist in the development and monitoring of the identified goals and objectives and to advise and make recommendation to OMPP. The members of the Quality Strategy Committee include: OMPP, FSSA, DMHA, ISDH, providers, health plan quality managers, advocacy groups, consumers, and members of academia. Having accomplished operational implementation of the EHR Incentive Program, OMPP is in the process of realigning its internal and external quality oversight and improvement processes to integrate reporting of CQMs and other measures of health care provider performance, update quality improvement strategies with its partner HIOs, Page 17 of 81

18 and identify the most productive way in which OMPP staff can utilize these measures and capabilities. B.4 Electronic Information Exchange Indiana has robust exchange of health information across the public and private stakeholders. OMPP administers the Medicaid program in Indiana and is the largest payer in the State and supports electronic information exchange for claims and measurement data. Information exchange is expanding across clinical care delivery providers, payers, and public data resources. Multiple data sources and data receivers are working collaboratively to provide technical services to facilitate the exchange of health information to improve data interoperability to improve secure and appropriate use of health data to inform treatment, payment, and population health. Indiana leveraged multiple funding Health Information Technology for Economic and Clinical Health Act (HITECH) grant opportunities advancing EHR technology adoption, connecting data sources, improving interoperability of health information, improving outcomes and measurement, and coordinating state and federal health IT initiatives. Indiana s Health IT and Exchange progress is noted below. B.4.1 Electronic Clinical Laboratory Ordering and Results Delivery Across Indiana, laboratories and providers are primarily using Directed Exchange to support electronic clinical laboratory results delivery. Historically, providers have used the electronic order entry hosted by laboratory providers outside of HIO web portals or EMR interfaces. However, the state s major HIOs are evolving with their architectures to begin to serve as hubs for lab ordering and results delivery; integration has been completed to enable results sharing between sub-state HIOs, and increased capacity to support ELR with public health. IHIT offered incentive payments for rural hospitals and clinics to connect to HIE infrastructure, either through sub-state HIOs or via direct messaging, to send and receive lab results. As a result of these incentives, over 92% of providers at Federally Qualified Health Centers (FQHC), Community Health Centers (CHC), and Rural Health Centers (RHC) were connected to an HIO at the end of DOCS4DOCS (D4D) is an electronic results delivery service provided by the Indiana Health Information Exchange (IHIE). It offers a single source for clinical information such as lab results, radiology reports, transcriptions, pathology and hospital admissions reports, discharge and transfer reports from all participating Indiana hospitals, physician practices, labs and radiology centers. Results can be viewed through a web-based portal or delivered directly into an electronic medical record system. IHIE s D4D Service is used by as clinical messaging application in which more than 25,000 providers in over 6,000 locations throughout Indiana receive clinical results as the ordering physician. IHIT worked to assist independent labs in establishing connectivity with the state s HIE infrastructure, including public health ELR. B.4.2 Exchange of Continuity of Care Information Efforts are currently underway to drive interoperability between the sub-state HIOs and expand the ability to deliver results and messages to any provider connected to one of the sub-state HIOs. All four of the HIOs accomplished this by launching shared provider directories and Direct-compliant transport by implementing Health Information Service Provider (HISP) protocols. As part of statewide interoperability initiatives, the sub-state HIOs Page 18 of 81

19 are leveraging Direct messaging as well as certified participants of the Sequoia Project ehealth Exchange (formerly known as NwHIN) Connect software standards to actively exchange consolidated care summaries using a continuity of care document (CCD) format. Using ehealth Exchange gateways, they are able to query other data sources to identify if additional information exists on a patient. Patient information is merged into a single document by the HIO initiating the query then delivered to the point of care via Direct messaging. Currently, approximately 38 of Indiana s hospitals are electronically sharing care summaries with unaffiliated hospitals and providers. To date, more than 9.7 million Admit-discharge-transfer (ADTs) and 650,000 CCDs were shared in 2016 alone. B.4.3 Broadband Internet Access and Telehealth Indiana received $16 million from the Federal Communications Commission's (FCC's) Rural Health Care Pilot Program, and as a result, created the Indiana Telehealth Network (ITN). Since 2010, ITN and the Indiana Broadband Mapping Project have received approximately $3.2M in federal grants. ITN formed an FCC Rural Health Care Steering Committee, which was made up of representatives from healthcare providers, telecommunication companies, representatives from the Indiana Office of Community & Rural Affairs, and representatives from the Indiana Rural Health Association, the lead entity for the ITN. The five year project was divided into three phases and the work successfully concluded in The table below presents a summary of the project phases. Table 2. Broadband Network Five-Year Summary Phase 1 Phase II Phase III Reduced bandwidth costs Reduced Primary Rate Interface (PRI) costs Doubled the speed of existing broadband connections 85% funding for construction of fiber to their hospitals Completed ability to transmit images Improved economic opportunities Expanded ability to conduct Telehealth encounters over a dedicated health care network Disaster Recovery E-Learning Internet Access Videoconferencing Seamless interfaces with the Indiana Health Information Organizations (HIOs) Overall, access to a wired connection of at least 10mbps has improved from 86.6% to 90.7% in Indiana. Meaningful Use objectives with an exclusion for broadband access require a connection of at least 4mbps for 50% of inhabitants within a 50 mile radius. In addition, 100% of Indiana residents have access to mobile broadband services and 78.6% have access to fixed wireless services. Approximately 2% of Indiana residents do not have any wired internet providers available where they live. Figure 1 below (next page) shows overall coverage for Indiana. Page 19 of 81

20 Figure 2: Indiana Broadband Coverage by County B.4.4 Regional Extension Centers (REC) Indiana had two (2) RECs that contracted with ONC: HealthBridge, currently part of the Health Collaborative, operated the Tri-State HIT Regional Extension Center (REC) Purdue Healthcare Advisors (PHA, formerly known as I-HITEC), operated by Purdue University. Through an additional funding match and a $250 per provider fee, PHA is guiding EPs through the EHR incentive program while helping them adjust to using their CEHRTs in a meaningful way. Since the additional work began in October 2014, PHA has worked and is currently working with 125 unique organizations representing approximately 1,020 EPs, many of those organizations enrolling in the assistance program for multiple EHR Incentive Program years. With the approval of the 2016 IAPD-U, PHA will secure a contract with FSSA to continue the work through September The scope of PHA includes statewide educational sessions including webinars and in-person sessions when requested. PHA monitors a dedicated and a call center open for participating EPs and providers with questions about eligibility and meaningful use. The dedicated and call center assist providers with varying types of issues as illustrated by Figure 2 below (next page). Page 20 of 81

21 Figure 2. Purdue Health Authority EP Help Desk Utilization As the work with EPs has evolved with the release of the Modifications to Meaningful Use in and Stage 3 Meaningful Use final rules, PHA has expanded their services to include security risk assessments and have made external vulnerability scans and technology wellness checks. PHA also provides direct assistance to FSSA in the administration and oversight of the Indiana Medicaid EHR Incentive Program. PHA works directly with the HIT Coordinator. PHA will administer web-based program satisfaction surveys on an annual basis. Results from the 2015 program satisfaction survey will be included in Section 4. Because PY 2016 will be the last year that EPs and EHs, including CAHs, can join the Medicaid EHR Incentive Program, PHA will continue outreach through newsletters, webinars, direct one-on-one conversations that come in via the call center and reminders at conferences and other stakeholder meetings. The 2016 e-scan provider survey results will be shared with PHA for use in further outreach. B.4.5 Beacon Community Grant In May 2010, Indiana received $16 million in grant funding for the Beacon Communities Cooperative Agreement Program administered by U.S. Department of Health and Human Services (HHS) and Office of the National Coordinator for Health Information Technology (ONC). Specific goals for the Central Indiana Beacon Community included 3 : Improve health outcomes for patients with diabetes by helping providers manage patient performance on measures of blood sugar and cholesterol; Improve health outcomes by increasing appropriate use of preventive services, such as immunizations and screening for cancers of the colon and cervix; Reduce hospital admissions and emergency room visits for patients with conditions that could have been treated in an outpatient setting; and Page 21 of 81

22 Strengthen health IT infrastructure and extending exchange capabilities to help physicians achieve measurable and sustainable improvements for patients. 3 Based on the Central Indiana Beacon Community fact sheet from healthit.gov. At the grant conclusion, more than 2.7 million patients were touched by a Beacon intervention administered by one or more of the 1,600 providers or 57 hospitals participating in grant activities. Colorectal cancer screenings increased by 8.5% to 66.02%, exceeding the goal of 60.42% and cervical cancer screenings have increased 3.24% to 81.38%. Diabetic patients with acceptable ranges of blood glucose levels (HbA1C) have improved by 3.5% and the number of diabetic patients with cholesterol levels in acceptable ranges increased by 1.5%. B.4.6 EvidenceNOW Advancing Heart Health in Primary Care The state of Indiana is currently participating in EvidenceNOW, an Agency for Healthcare Research and Quality (AHRQ) grant initiative launched in May 2015 and continuing through May This initiative assists small- and medium-sized primary care practices in using the latest evidence to improve heart health and contribute to the national effort of preventing 1 million heart attacks and strokes by Purdue Health Authority (PHA) is leading the recruiting and improvement efforts led by Northwestern University s School of Medicine. PHA is assisting nearly 50 small practices around the state in improving their Million Hearts cardiovascular measures around aspirin therapy, blood pressure control, cholesterol management, and smoking cessation. EvidenceNOW consists of two main goals: improving the delivery of heart health care across the country and understanding what type of supports help primary care practices achieve these improved health outcomes. Additionally, the initiative has an aspirational goal that each involved practice will meet the national target of having 70 percent of all patients adopting the ABCS of cardiovascular health. Indiana, Illinois, and Wisconsin make up the Midwest cooperative. The Midwest cooperative has a target of recruiting small- and mediumsized, independent primary care practices. Additionally, the AHRQ has awarded a grant to the Oregon Health and Science University to conduct an independent national evaluation of the overall EvidenceNOW initiative. B.4.7 Transforming Clinical Practice Initiative One of the largest federal investments designed to support clinician practices through nationwide, collaborative, and peer-based learning networks is the Transforming Clinical Practice Initiative (TCPI). These peer-based learning networks known as Practice Transformation Networks (PTN) are designed to coach, mentor, and assist clinicians in developing core competencies specific to practice transformation. This will allow clinician practices to become actively engaged in transformation and collaboration within a broad community. This initiative was aided by the Affordable Care Act (ACA) to strengthen the quality of patient care and spend health care dollars more wisely while aligning with the criteria for innovative models set forth in the ACA. The University was awarded $46.4M by the U.S. Department of Health and Human Services and is working with the Regional Extension Center, seven additional universities, three state Health Departments and Indiana s four HIOs. Purdue Health Authority is leading Indiana s efforts for the Great Lakes PTN, led by the Indiana University School of Medicine. In this role, PHA coordinates and serves as a key delivery member for much of the value-based care transformational assistance for over 3,400 providers throughout Indiana. Page 22 of 81

23 B.5 Electronic Public Health Reporting The Indiana State Department of Health (ISDH), in conjunction with FSSA/OMPP, has been actively planning for the changes to Meaningful Use and advancing health information exchange through specialized registries such as the immunization registry and the cancer registry. ISDH is working with FSSA to submit an Implementation Advanced Planning Document (IAPD) to enhance and evolve the immunization system to better support Indiana providers and citizens while advancing health IT in Indiana. B.5.1 Emergency Surveillance System Indiana s Public Health Emergency Surveillance System (PHESS) was established over a decade ago by the Indiana State Department of Health (ISDH) in partnership with the Regenstrief Institute. It electronically links Indiana s hospital emergency departments to the ISDH to create a statewide, standards-based public health surveillance system. A component of PHESS, the Electronic Surveillance System for the Early Notification of Community-based Epidemics (ESSENCE), is used by healthcare providers for reporting specific cases of communicable diagnosis to health departments. Support for the PHESS system is ending in June 2016 since current guidance doesn t require syndromic event types. The PHESS system will be maintained and access available; however further evolution of the PHESS system is no longer supported. B.5.2 Immunization Registry The Children and Hoosier Immunization Registry Program (CHIRP) was established in 2002 under Indiana Codes IC as a web-based electronic database to collect immunization records for individuals of all ages in Indiana. By centralizing immunization records, individuals in the state now have access to their records through private providers, local health departments, and schools at no cost to the consumer, including Indiana providers. CHIRP is able to communicate bi-directionally; however, it not yet able to communicate in real time. All received messages are stored and batched nightly, causing a moderate delay. ISDH is currently working with FSSA on an Implementation Advanced Planning Document (IAPD) for a real-time bi-directional interface with a target completion date of late CHIRP has become a valuable resource to the more than 9,000 active users, including providers and citizens of Indiana by reducing staff time spent on searching for immunization records, tracking vaccine inventory and providing a more complete immunization history. The registry provides a suggested immunization schedule and, through My VaxIndiana, a secure consumer portal implemented in 2012 by OMPP in collaboration with ISDH, citizens can print and save their immunization records. This initiative links My VaxIndiana to HIO-sponsored Personal Health Records (PHR) via Direct Messaging. ISDH serves as the Public Health Authority (PHA) for the State of Indiana and as such, provides assistance to EPs, EHs and CAHs participating in the EHR Incentive Program. CHIRP can currently accept, validate and document provider attestations for Meaningful Use, including the Modification to Meaningful Use final rule. There are currently 141 hospitals linked to CHIRP both via direct data entry or HL7; 117 are connected using HL7 messaging and 109 have successfully attested to Meaningful Use. In additional, there are over 700 providers in production. All but Page 23 of 81

24 one of Indiana s 92 counties have access to CHIRP including all of the Indiana Local Health Departments. As of June 2016, CHIRP receives an average 16,000 HL7 Unsolicited Vaccination Record Update (VXU) messages, approximately 100,000 per week. B.5.3 Electronic Laboratory Reporting and Syndromic Surveillance Electronic Laboratory Reporting (ELR) and Syndromic Surveillance have been very successful objectives for Indiana hospitals. Approximately 91% of ISDH s reportable conditions are transmitted via ELR using an HL7 message with 83% of these meeting Meaningful Use Stage 2 requirements. More than 180 hospitals are linked and ISDH is currently planning to update their 410 IAC (Indiana Administrative Code) rule to achieve 100% electronic submission of ELR. All hospitals with emergency departments are currently reporting syndromic surveillance. Recently, two urgent care facilities linked with a larger hospital system have begun reporting syndromic surveillance. EPs participating in the Medicaid EHR Incentive Program are exempt from the syndromic surveillance reporting requirement; however, FSSA and ISDH have recognized that there is a large potential for expanding beyond hospitals and including more urgent care facilities and ambulatory providers. B.5.4 Cancer Registry With the changes to the public health reporting objective in the Modifications to Meaningful Use final rule, there has been an increased interest in the Indiana State Cancer Registry. Between June 2015 and June 2016, 55 EPs have indicated their intent to send files for MU Cancer Reporting, 16 EPs have sent files to the Cancer Registry, and 406 files have passed validation. B.5.5 HIE Network Support Indiana HIE s and hospitals participate in the Public Health Emergency Surveillance System (PHESS) network, the statewide infrastructure to analyze primary complaint data from Indiana emergency departments for the early detection of acts of bioterrorism and other public health emergencies. Currently, 120 Indiana emergency departments (ED) are connected. Additionally, the HIE networks support Communicable Disease Reporting by leveraging the developed Notifiable Conditions Detector (NCD), an ONC-certified technology for electronic lab reporting, to identify list of communicable diseases with positive results and flagged to be sent to ISDH. Indiana HIEs can also document immunization information at point of care, and immunization administration information is reported to CHIRP. B.6 Statewide HIE Networks There are four established health information exchange networks operated by Health Information Organizations (HIOs) that currently serve Indiana and, in some cases, border-states and regional partners. These HIE networks were developed initially with a majority of hospital participation, although they continue to expand their provider outreach efforts especially in the context of the EHR Incentive Program. Each network has distinct characteristics in terms of their geographic region, participants, and business model. Page 24 of 81

25 Networks currently in existence in Indiana are listed in Table 3, below: Table 3. Major Indiana Regional Health Information Organizations/Networks Regional Network Providers Covered Status HealthBridge Greater Cincinnati tristate area physicians Operational HealthLINC Indiana Health Information Exchange (IHIE) Michiana Health Information Network (MHIN) Physicians in Lawrence, Monroe, Orange, and Owen counties Represents hospitals, healthcare providers, researchers, public health organizations and economic development groups Over 3,000 physicians in northern Indiana and southwestern Michigan Operational Operational Operational B.6.1 HealthBridge HealthBridge has offered operational health information exchange since Its mission is to build a collaborative network of organizations and technology to improve the quality and efficiency of health care delivery. Recently, HealthBridge became part of a team of organizations called the Health Collaborative, working together with the Greater Cincinnati Health Council to advance health care transformation and the Three Part Aim of better care, better health, and lower costs. HealthBridge serves a primary service area in the Greater Cincinnati tristate area that includes four Indiana counties. HealthBridge has more than 7,500 physicians in its provider directory and 3.0 million patient records, with approximately 3-5 million electronic messages per month, including clinical lab tests, radiology reports, and discharge summaries. B.6.2 HealthLINC HealthLINC is a community-based organization that has offered operational health information exchange since 2007 to healthcare stakeholders in Lawrence, Monroe, Orange and Owen counties. Recently, HealthLINC became a community partner with The Health Collaborative, sending greater than 110,000 secure clinical results per month. HealthLINC is a true community collaboration that includes 85% of community physicians representing more than 400,000 patients records in its community patient index. HealthLINC continues to make special efforts to improve care coordination for under-served populations including the uninsured and patients with chronic mental illness. HealthLINC also analyzes statistics including total results per month per practice, results per month at the community level and the number of practices with clinical messaging. HealthLINC has created a health service directory that includes more than 285 physicians, 4 regional hospitals, 4 long term care facilities, a surgery center, and a clinic-based regional laboratory setting the stage for care coordination improvements using HIT and EHRs. Page 25 of 81

26 B.6.3 Indiana Health Information Exchange (IHIE) IHIE is a tax-exempt, nonprofit corporation founded in 2004 with 111 Indiana hospitals, approximately 33,500 healthcare providers, researchers, public health organizations, and economic development groups representing over 18 million unique patients. IHIE is a leading provider of scalable health information exchange services with demonstrated and sustainable technologies and processes. IHIE hosts one of the nation s largest inter-organizational clinical data repository, a patient-centric community health record for millions of Indiana citizens. This resource is an aggregated clinical data for a patient or a population and includes provider, payer, and public health data from real-time interfaces from providers providing labs, radiology, CCDs, transcriptions, cardiology information, and ADTs. This information is utilized heavily in hospital emergency departments, but also in a growing number of clinical and population health management settings, including medical research. Figure 3 below demonstrates IHIE s geographic coverage area in Indiana. Figure 3. IHIE Geographic Coverage Area B Multi-stakeholder Private Governance Each participating provider signs a Participant Agreement and participates in the committee discussing and determining the functioning rules of the sharing information across the Indiana Network for Patient Care (INPC ). This group determines the approved use cases for sharing, accessing, and using information across IHIE participating organizations. This private HIE governance body is only for IHIE participants, and FSSA has a seat on the Management Committee of the INPC. Page 26 of 81

27 B Current IHIE Services of the Indiana Health Information Exchange Sequoia Project ehealth Exchange - IHIE has expanded use of the ehealth Exchange for automated Social Security Administration (SSA) disability determination via electronic request and record retrieval of INPC data through the ehealth Exchange. IHIE fulfills about 100 SSA applicant requests per day; previously, manual record gathering took 4 months to 3 years. Additionally, Indiana health providers can share veteran s clinical data via the ehealth Exchange as part of the VLER program. IHIE supplies about 90% of the clinical data that the VA receives from ehealth Exchange trading partner; and IHIE data has been accessed in all 50 states. IHIE supports eligible professional and hospitals Meaningful Use Stage 2 Transitions of Care requirements as directed by Meaningful Use Stage 2 guidelines by being an officially on-boarded ehealth Exchange participant enables us to offer customers Transitions of Care, taking advantage of existing HIE infrastructure. Participating Indiana HIEs support the ehealth Exchange use cases: o o o SSA Disability Determination - IHIE has expanded use of the ehealth Exchange for automated SSA disability determination via electronic request and record retrieval of INPC data through the ehealth Exchange. IHIE fulfills about 100 SSA applicant requests per day; previously, manual record gathering took 4 months to 3 years. Veteran s Affairs Data Exchange with VLER - Indiana health providers can share veteran s clinical data via the ehealth Exchange as part of the VLER program. IHIE supplies about 90% of the clinical data that the VA receives from ehealth Exchange trading partner; and IHIE data has been accessed in all 50 states. Meaningful Use Stage 2 Transition of Care Requirements - IHIE supports eligible professional and hospitals Meaningful Use Stage 2 Transitions of Care requirements as directed by Meaningful Use Stage 2 guidelines by being an officially on-boarded ehealth Exchange participant enables us to offer customers Transitions of Care, taking advantage of existing HIE infrastructure. ACO & Population Health Services - In addition to ehealth Exchange, IHIE s ACO & Population Health Services, ADT registration alerts are available in any care setting. These ADT alerts support event notification for multiple use cases including emergency room admission, hospital discharge, or ambulatory encounter event. Event notifications are available from HIE participants and can be sent for a specific patient list to managed care organizations, care coordinators, and care teams for follow up care coordination. IHIE also provides a Clinical Data Report including 36 approved data elements. The Clinical Data Report is accessible by clinical care team members. INPC has approved access to Care Managers to include expanded care team members and to assist care coordination work using IHIE data. Reports delivered daily with information on when patient presented for care and diagnosis as well as approved lab value information. B.6.4 Michiana Health Information Network (MHIN) MHIN was formally established in 1998 with the mission to provide single source, secure access and delivery of medical information leading to the care and quality of a person. MHIN serves over 13,000 physicians, representing 356 participating organizations/clinics including hospitals, clinics, skilled nursing facilities, ACOs, laboratories, alcohol and drug treatment centers, and behavioral health clinics. These participating organizations represent over 1.8 Page 27 of 81

28 million patients across northern Indiana and southwestern Michigan. To date, MHINs network has had approximately 420,000 CCD exchanges. B MHIN Population Health Strategic Plan MHIN s population health strategic plan includes an ambitious research agenda that considers future changes around shifting community priorities, emergent unforeseen health needs of the community, and funding opportunities. The plan s purpose lies in improving the health of local communities by outlining priority areas of population health focus and accommodating the significant shifts seen in the health landscape within the U.S. in the last several years. MHIN has created the MHIN Data Set of Social Determinants of Health which was derived from traditional medical information collected in EHRs. MHIN plans to implement this population health strategy over the next three years, concentrating on using the Data Set of Social Determinants to inform and enhance its Bio-Surveillance efforts, Remote Monitoring, and selected Regional Health priorities. Throughout this plan, MHIN will be working with academic researchers, industry experts, utilizing bleeding-edge technology, and evidence-based methodologies to identify, acquire, and operationalize the MHIN-specific Data Set of Social Determinants of Health with the goal of integrating it into the regional exchange and analysis of health data, to improve the capacity of our provider and public health system. B.7 Core Interoperability Projects IHIT created five projects with each HIE and project plans for each category of development. In addition to these first five projects, OMPP worked with funds made available through the Challenge Grant program to fund three additional projects that play a part of the roadmap. Many of these projects have ongoing work and will be highlighted in the State HIT Roadmap section. Project 1: HIE to HIE Connectivity Messaging Project 2: HIE to HIE Connectivity Bi-direction Summary Record Exchange Project 3: Public Health Connectivity and Exchange Project 4: Standards and Normalization Project 5: HIE Longitudinal Patient Record Incentive B.8 Current HIE Architecture/Structure The current As Is HIE architecture is depicted below and identifies the four HIOs participating in statewide HIE and data sharing within the State of Indiana. The depiction below also represents the complex relationships between the data users and HIE service entities. The foundation (blue ellipses) of the HIE model is the data service users. There are three types of users represented: physicians/clinics, hospitals and payers. The mezzanine is supported by four exchange network s infrastructure. HealthBridge and HealthLINC are illustrated as one support because HealthBridge provides the infrastructure and connectivity for HealthLINC. CMS and the SDE are represented outside of the structure illustrating their regulatory and standard-setting functions. Page 28 of 81

29 Figure 4. Indiana HIE Network Structure B.9 Governance for State Health Information Exchange In carrying out its former leadership and coordinating role for the state, as designated by the Governor, IHIT developed a governance model and instituted a formal governance structure that leverages private sector HIE development while ensuring strong state direction and multi-stakeholder collaboration. Indiana s current statewide HIE governance leveraged the state-led HIE governance structure and processes and built well-established governance models continued by its four major private sector HIOs, an infrastructure that is already continue to oversee stakeholder involvement and the provision of many of the required HIE services. IHIT focused and directed the efforts of the HIE stakeholders - Indiana HIOs, state agencies, HIT vendors, providers and consumers - in four strategic areas: Connecting Data Sources, Interoperability, Improving Outcomes, and Federal/State Initiatives. Through IHIT s formal structures, processes, and policies, Indiana s Health IT stakeholders continue to expand on these foundations and to strengthen information exchange across Indiana. Most significantly, the blended strong public and private sector representation and distributed approach to governance that built on the wellestablished HIE governance structures and processes of Indiana s four HIOs. Page 29 of 81

30 As an active stakeholder in the distributed governance structure, FSSA currently participates with Health Information Exchange Task Force convened by the Indiana Hospital Association. This group contains 25 hospital representatives who work with data and information needs within their organizations. This includes CEOs, CIOs, market analysts, quality directors, and other interested parties. FSSA also holds a seat on IHIE s management committee facilitating expanding HIE use cases in line with Indiana s key Health IT strategic areas. B.10 Veterans Administration and Indian Health Services Providers There are two federal health care delivery systems in Indiana. The Richard L. Roudebush VA Medical Center in Indianapolis, Indiana, is a part of the Veterans in Partnership integrated healthcare network delivery system providing primary care, specialty care, extended care, and related services to veterans. The Camp Atterbury Medical Treatment Facility (MTF), a user of VISTA EHR technology, is located near Edinburgh, Indiana. Under a pilot project between IHIE and the US Department of Veteran Affairs, the ehealth Exchange gateway was used to share information electronically to support health care services provided both at Roudebush and by private health care providers in Central Indiana who signed up on a voluntary basis for the HIE service. Subsequently, the four Indiana HIOs also established connections via the ehealthexchange using the Connect Gateway. Indiana has no enrolled Indian Health Services (IHS) providers at this time. B.11 Medicaid Information Technology Architecture (MITA) During , the State conducted a MITA self-assessment that included the HIT business unit, as per the finalization of the MITA 3.0 business process model and related self-assistance guidance. The current MMIS project demonstrates the State of Indiana s commitment to move its Medicaid enterprise systems up the MITA capability maturity ladder and line up the State s Medicaid enterprise systems more closely with the Seven Standards and Conditions for IT development (modularity, industry standards, reuse/leverage, business results, etc.) promoted by CMS. Moreover, the State s commitment to leveraging IT capabilities across programs and even states is illustrated by the adoption of MAPIR. B.12 MMIS HIT/HIE Environment Indiana s current MMIS is built on a nearly twenty-year old platform known as IndianaAIM. The current system uses batch processing and flat-file data transfers for interoperability, and does not perform real-time transactions. The current system is in the process of being replaced with new technology capable of enhanced automation and more efficient/economical processing capabilities in the future. Technical capabilities anticipated to be provided by the system will include: enhanced workflow, web services, a rules engine, and an enterprise service bus. The new system will have an inherent EHR capability to enhance and/or streamline many functions currently performed including care management and prior authorizations. OMPP s timeline is to have the replacement MMIS in production by the end of OMPP will share services in a standard format when the data is used to promote care coordination for Hoosier members and/or transmitted to achieve EP, EH or CAH Meaningful Use requirements. Maintenance of the Health Page 30 of 81

31 Insurance Portability and Accountability Act (HIPAA) and the ARRA security standards for receipt and transmission of the health information is a priority for OMPP, IHIE, and stakeholders participating in the statewide HIE network. Data will be exchanged for purposes of treatment, payment and program operations in accordance with HIPAA requirements. B.13 Summary of Medicaid Environmental As Is E-scan In early spring 2016, FSSA contracted the services of Myers and Stauffer LC (MSLC) to conduct an e-scan to inform on the state of HIT and EHR adoption in the State of Indiana. Outreach for the e-scan included: Online survey to EPs, EHs and CAHs; One-on-one interviews with statewide stakeholders; Interviews with statewide partners including HIOs and Purdue Healthcare Advisors; and Interviews with coordinating state agencies. B.13.1 Survey Strategy Two surveys were developed to communicate with specific provider groups: one for EPs (both participating and non-participating providers in the EHR Incentive Program) and one for EHs (both participating and nonparticipating hospitals in the EHR Incentive Program). MSLC used the previous survey as a guide, using the Survey Monkey tool because of its ease of use and consulted with its Health IT, Meaningful Use and Incentive Program subject matter experts to compose the EP and EH surveys. Working with oversight from FSSA and the HIT Coordinator, MSLC partnered with Purdue Health Authority to disseminate the survey as widely as possible. In addition to promoting the survey in newsletters and webinars, PHA reached out to numerous organizations and associations to aid in the dissemination of the survey link. Some of these entities include: Indiana chapters of the American Academy of Pediatrics, American College of Cardiology, American College of Physicians and the American College of Surgeons. The American Congress of Obstetricians and Gynecologists (District V), the Fort Wayne Medical Society, the Indiana Academy of Family Physicians, the Indiana Association of Healthcare Quality, the Indiana Health Information Management Association, Indiana Hospital Association, Indiana Primary Health Care Association, Indiana Rural Health Association, Indianapolis Medical Society, Indiana Neurological Society, and the Indiana HIOs were also notified of the survey and asked to aid in the dissemination. B.13.2 Survey Limitations The sample size is greater than the original e-scan from 2010/2011; however, it does not represent the entire provider population of Indiana. In order to round out the picture of EHR adoption and HIT/HIE in Indiana, FSSA and MSLC conducted numerous one-on-one interviews with stakeholders including the Indiana Health Care Association, Indiana Hospital Association, Indiana Health Information Exchange, the Division of Mental Health and Addiction, Indiana State Department of Health, Indiana Association for Rehabilitation Facilities, Indiana Council of Community Mental Health Centers, Purdue Health Authority, and the Indiana Rural Health Association. Page 31 of 81

32 B.13.3 As Is Eligible Professional E-scan The EP survey did not limit the recipients of the survey link to only those providers eligible for the Medicaid EHR Incentive Program resulting in a large variety of provider type responses. Because there were no limitations, 173 responses were received representing over 1,300 health care providers in the state of Indiana. The five categories of Provider Type provided in the survey were Medical Care General Practice (GP, FP, Internal Medicine, Pediatrics, PA, NP, RN), Medical Care Specialist (GI, ENT, Cardiology, Oncology, OB/GYN, Ophthalmology, Etc.), Behavioral Health Psychiatrist, Psychologist, Psychoanalyst, Social Worker, Dental Dentist, Family Dentist, Dental Surgeon, and Other. Table 4 - Indiana Provider SMHP Survey Provider Type Responses Provider Type Category Percent of Responses Medical Care - General Practice (GP, FP, Internal Medicine, 33.92% Pediatrics, PA, NP, RN) Medical Care Specialist (GI, ENT, Cardiology, Oncology, 11.11% OB/GYN, Ophthalmology, Etc.) Behavioral Health Psychiatrist, Psychologist, 12.87% Psychoanalyst, Social Worker Dental Dentist, Family Dentist, Dental Surgeon 13.45% Other 28.65% If a survey responder chose Other, the survey prompted for a specification in the provider type. Asking for a specific type when Other was chosen allowed for a broader view into the provider landscape, EHR adoption and HIE adoption. Provider type specifications when Other was chosen included home health providers, physical, occupational and speech therapists, long term care providers, chiropractors, EMT and ambulance services, hospice, and optometrists. A little over 97% of the practices that responded to the survey serve Medicaid patients with 38% percent of those practices indicating that more than 50% of their patients are enrolled in Medicaid. Unlike the EH respondents to the survey which will be summarized in the following section, the majority of practices still maintain some form of a paper chart. Seventy-five percent (75%) of responding practices use an EHR with 84% of those practices using a Certified EHR. Approximately 46% of practices that responded do not maintain paper charts and 16% of practices that responded primarily use paper charts but do record some clinical data electronically. The higher number of practices that maintain paper charts at various levels may be due to the larger number of non-eligible professionals that responded to the survey and may be seen as an opportunity to expand EHR adoption outside of the primary care arena. The EP survey asked respondents to share the three most significant ways that the EHR has hindered the care provided to patients along with the three most significant ways that EHRs have improved the care of their patients. As we have seen since the inception of the EHR Incentive Program through the technical assistance provided through the RECs, the three largest complaints center around lack of training, workflow changes and the time spent entering data while attending to the patient. Although there are still some challenges adapting to EHRs, Page 32 of 81

33 62% of respondents agreed that the use of their EHR facilitates access to and use of the patient health data among members of the health care team while 44% noted that the use of the EHR reduces errors and 41% said that they believe the EHR improves the quality of patient care. Since the original survey performed in the previous e-scan, Meaningful Use efforts have helped interoperability progress as well as patient engagement to allow more patients to access their health information through a patient portal as well as other time-saving tasks leading to a higher level of patient portal usage. Of the practices that indicated they provide patient portal access, 70% of them report that the patient portal is accessed mostly for lab results while 60% of practices noted that the patient portal is used secondarily for prescription refills and appointment scheduling. Lastly, the EP survey asked respondents to answer a few questions about HIEs and participation in one or more of Indiana s four HIOs. One hundred and one survey respondents shared whether or not they have joined an HIE with 61% of the EP practices indicated that they have not primarily because the larger HIEs in Indiana do not currently provide EHR integration with many ambulatory EHRs and that the primary focus has been on hospital participation. Of the 33 respondents that shared which functions would enhance their return on investment for their chosen HIE, 70% said that bi-directional exchange with other ambulatory providers would be the best enhancement. Clinical quality measure collection and reporting was a priority for 52% of the respondents while 45% suggested integration with claims data. B.13.4 As Is Hospital E-scan Like the EP survey, the EH survey was not limited to hospitals eligible for one or both of the EHR Incentive Programs and received 37 responses. Of the responses, there were 23 community hospitals, 4 CAHs, 4 behavioral health/mental health hospitals, and 3 public hospitals. EHR adoption is high among the survey respondents with 34 of the hospitals having a certified EHR in use, one hospital in the process of implementing a certified EHR and only one hospital with no plans to adopt due to the lack of specialized software for their patient population. Much like the EP survey, EHs reported the workflow design is their greatest barrier along with increased difficulty in Meaningful Use objectives and the implementation and use of the patient portal (a Meaningful Use Stage 2 requirement). The majority of the EHs eligible for the Medicaid EHR Incentive Program have already received three payments and is no longer eligible for additional payments. Even though the EHs said that the patient portal was a barrier for them, 92% of respondents indicated that they do offer a functioning patient portal and it is used primarily for accessing lab results (96%) with downloading discharge instructions at 57% and billing information at 44%. EHs, like EPs, were asked to share the three most significant ways that the EHR has hindered the care provided to patients along with the three most significant ways that EHRs have improved the care of their patients. EHs indicated that the time to train and time to convert old records are two of the greatest hindrances. Fifty-four percent (54%) of hospital respondents also noted that system incompatibility and interoperability are also challenges. EHs did note that EHRs reduce errors (88%), facilitate access to and use of patient health data among members of the health care team (79%), and that information from the EHR enables better decision making in patient care (50%). Lastly, the EH survey asked about HIE participation by hospitals in Indiana. HIE participation amongst hospitals is Page 33 of 81

34 very high with 83% of the respondents indicating they ve joined an HIE. Three hospitals said that they haven t joined because of vendor readiness, not enough participation with coordinating providers and cost. The EH survey asked which HIE each EH participates in and 94% of the EHs indicated that they subscribe to IHIE. EHs were asked which functions would enhance their return on investment for their chosen HIE and 75% of the respondents said bi-directional exchange with ambulatory providers would be the greatest enhancement with 63% responding that integration with claims data would be another valuable enhancement. Figure 5 from the IHIE website below demonstrates HIE connectivity for Indiana hospitals. Figure 5. Indiana Hospitals with HIE Connectivity Page 34 of 81

35 C. Indiana s To Be HIT Landscape Indiana continues its vision for electronic health records (EHR) adoption and implementation and widespread, robust exchange of health information to improve health and health care for Indiana. The vision was crafted based on an appreciation for the Indiana culture of marketplace innovations. The early direction for Indiana s HIT development was shaped by the private sector, forged by the successful efforts of the nation s leading HIOs, IHIE and HealthBridge. The HITECH Act and the State Health Information Exchange Cooperative Agreement Program (SHIECAP) provided the impetus to coalesce Indiana s vision into a strategic plan and operational pathway toward the future To Be HIT landscape, building on a foundation of HIE business acumen, and policy leadership provided by FSSA. The designation of Indiana Health Information Technology, Inc. (IHIT) as the leading governance entity for Indiana s HIT and HIE efforts provided a formal bridge between sectors, and a venue for collaborative, negotiated HIT and HIE solutions that has now transitioned to FSSA leadership. Public and private stakeholders continue as integral partners in the governance, development and operations of Indiana s developing statewide health information system. The Indiana Strategic and Operational Plans submitted to ONC under SHIECAP identified HIT and HIE capacity development to goals for improving health care, including for those served by Medicaid and other public programs. The SHIECAP remains the key state strategy coordinating public and private Health Information Technology and Exchange strategies. Additionally, Indiana s MMIS implementation with estimated late 2016 completion supports the State s management of its public programs in conjunction with the HIT and HIE assets developing across the broad landscape. As mentioned earlier, ISDH, in conjunction with FSSA/OMPP, has been actively planning for health information exchange through specialized registries such as the immunization registry and the cancer registry. ISDH is working with FSSA to submit an Implementation Advanced Planning Document (IAPD) to enhance and evolve the immunization system to better support Indiana providers and citizens while advancing health IT in Indiana. The To Be HIT Landscape will build on efforts outlined in the Strategic and Operational Plans, MMIS implementation and capabilities, the planned HIE IAPD, and the EHR Incentive Program operations. Continued provider adoption of certified electronic health record technology will improve point of care access to health information for Indiana Medicaid members and providers. Expanded HIE technical services providing timely access to health information across organizations continue to facilitate coordination of care. Additionally, as more providers health data systems are connected to the developing health information network, clinical data aggregation will support advanced data sets for advanced population health measurement. This will help improve the quality and cost-effectiveness of health care provided for individuals and families and of the Indiana health care system as a whole. C.1 Public-Private Stakeholder Cooperation Public and private stakeholder cooperation is essential for executing Indiana s vision for HIT. This cooperation includes a flexible, inclusive, and effective governance structure engaging diverse stakeholders across sectors and network aligned to common objectives. Indiana Health Information Technology, Inc. (IHIT) previously played this critical role to ensure that all stakeholders participate and are served by HIT and HIE services. As a non-profit, state- Page 35 of 81

36 level governance and coordinating entity, IHIT built on the experiences of previous HIT stakeholder collaborations including: the Indiana Health Informatics Corporation (IHIC), a public instrumentality created in 2007 under statute by the State of Indiana to guide and promote health information exchange within the State; the State HIE Collaboration began in 2008; and the Exhibit Indiana initiative coordinated by BioCrossroads, to establish a convening and coordination structure and governance processes for generating multi-stakeholder buy-in and the trust necessary for effective public-private collaboration. IHIT captured lessons learned from these efforts as its formal structures and processes were crafted. Most significantly, IHIT provided a venue that blended strong public and private sector representation, and used a distributed approach to governance that built on the well-established HIE governance structures and processes of Indiana s four HIOs. The cooperative HIT and HIE governance structure will continue to leverage the well-established HIE governance structures and processes. FSSA continues to be a key stakeholder and attends privately convened stakeholder groups, including the Indiana Network for Patient Care (INPC ) and the Indiana Hospital Association s HIT advisory Council on Information Management and Health Information Task Force. As objectives develop, additional stakeholders will be identified to join the existing convening groups to facilitate new or extended technical services. FSSA will also support internal OMPP EHR Incentive program workgroups and other Medicaid IT system coordination connecting the internal Medicaid enterprise planning to the external, private stakeholders as needed to support a broadening Indiana health information network. Additional state agencies, such as ISDH will engage FSSA and the external HIT community to coordinate advancing Health IT and Exchange strategies. C.1.1 HIT Coordinator The HIT Coordinator is located within FSSA and reports to the Chief Information Officer (CIO) and oversees all HIT related initiatives for the state of Indiana. This role embodies a collaborative multi-sector approach. The HIT Coordinator brings sectors and interests together to consider policy goals for improving health care including for Medicaid and CHIP, and continuously focusing and facilitating the efforts of the four Indiana HIOs, providers, vendors, agencies and stakeholders at large on the four strategic pillars of Indiana s Strategic and Operational Plans: connecting data sources, fostering interoperability, improving outcomes, and leveraging Federal/State Initiatives. Additionally, the HIT Coordinator provides staff guidance on Medicaid s role within the HIE, and provides vision and direction for the EHR Incentive program with regards to (a) meaningful use realization and acceleration and (b) the role of HIE in achieving this goal. This role provides vision and guidance to Medicaid on leveraging HIT program goals with existing programs, and assists with work plans and resource management, program metrics/operations and performance management. The HIT Coordinator makes operational recommendations for HIT initiatives, and serves as the primary contact with CMS and ONC for HIT and HIE efforts as mentioned above. C.2 Vision for HIT Environment In its Strategic and Operational Plans, Indiana lays out four (4) strategic pillars that serve as the vision and pathway for the state s HIT environment: connecting data sources, fostering interoperability, improving outcomes, and leveraging Federal/State Initiatives. Page 36 of 81

37 As national standards further develop and through the various targeted projects underway, the state will continue from IHIT s efforts to work with the HIOs to foster increased interoperability, data standardization and security. Building from efforts being driven by private market trading partner agreements, IHIT and its partners leveraged additional open source tools and specifications (e.g. Direct and the Connect Gateway) developed as part of the Sequoia Project ehealth Exchange. The strategies formerly pursued by IHIT and its partners, and the continuation of these activities by FSSA, EPs and EHs (including CAHs) will continue to gain and expand connectivity and the ability to exchange health information within and outside their HIO for the purposes of treatment, payment, and health plan operations (TPO). A comprehensive strategy for expanding interoperability through the HIOs is designed to ensure that the adoption of certified EHR technology will target eligible professionals and hospitals but encompass other health care providers and the industry at-large. Interoperability for individual providers outside of an HIO ecosystem will be accelerated by providing secure HIE messaging for clinical information between health care providers, enable the capture of core information to facilitate care coordination and point of care decision making, and will foster more timely access to care for Hoosiers without delays while reducing the administrative burden of paper-based exchanges. As the majority of providers are gaining active status as participants in the EHR incentive program, demonstrating meaningful use and the reporting of Clinical Quality Measurements (CQM) will continue to be the prevailing priorities as Stage 2 and Stage 3 requirements are instituted. Organizing an integrated quality reporting strategy is an important ongoing focus, seeking to build upon developing cross-hio querying of repositories and other strategies currently in play to expand and enhance interoperability of clinical data. The public health opportunities associated with building the capacity of the statewide HIE network are immense. The State Immunization registry and public health surveillance reporting database are two examples of databases that can be populated with information that is gathered through the HIOs. Many providers are already required to submit multiple files for secondary uses by public health officials for monitoring and reporting purposes. FSSA is actively working with ISDH on a public health HIE expansion leveraging the EHR Meaningful Use Incentive Program. ISDH has identified the following improvements to public health and public health data systems: More complete and accurate information (data quality) Improved coordination of care Improved responsiveness to communicable disease outbreaks. Healthier patient populations and communities Standards for quicker implementation and transmission of MU data. Funds to support facilities move to electronic and upgrade their feeds. Ability to transfer health information easily between Local Health Departments, other states, and federal partners. Exponential growth in storage costs. Medicaid has confirmed a contractor to replace the existing MMIS system to be in production by The new MMIS will contain an enterprise service bus, a rules engine, and workflow management components. Provider and member portal capabilities will continue and provide stakeholders with a mechanism for managing their Page 37 of 81

38 demographic information and the capability to obtain access to Medicaid policy rules and submit claims/encounters. Both Indiana Health Information Exchange (IHIE) and HealthBridge currently have connections to the ehealth Exchange. In the future Indiana will need to maintain the sustainability of the HIO structure that has occurred over the past 15 years. Integration of the HIOs will be driven by the private sector needs and desire of Indiana health care providers for data sharing relationships to facilitate exchange of ephi for TPO and to monitor health care outcomes. FSSA recognizes that the agency will play a significant role in transforming health care in Indiana and has developed its vision for HIT to address many of the challenges of integration with the HIOs. Obtaining and leveraging new technology is a key component. Implementation of a new MMIS is a major priority for providing improved functionality that will support OMPP and statewide HIT/HIE efforts. Indiana s vision for HIT also relies heavily on utilizing meaningful use of clinical information obtained through adoption, implementation and upgrade of certified EHR systems by providers and facilities and leveraging HIO technologies currently in place in Indiana. Through the use of EHR systems, HIE and other technologies described in the following sections, OMPP is positioned well over the next three to five years to significantly impact the following shared goals, initially established in IHIT s Strategic Plan: Connect data sources; Interoperability; Improve outcomes; Establish secure statewide and interstate HIE; and Focus on prevention. Realizing these broad goals for IHIT and its stakeholders includes the following eight components and related strategies: Table 5 Components of Indiana s Strategic Plans Shared Goals Components 1. Simplified access to Health Care Information and Services for Beneficiaries Projects Enhance secure web-based Beneficiary information, communication, outreach, and tracking Provide enhanced provider online search capabilities Improve service delivery through Interactive Voice Response (IVR) and VOIP (Voice Over Internet Protocol) technologies where possible Design and implement online capabilities to enhance quality consumer directed access to care Development of strong Medical Home delivery system Page 38 of 81

39 Components Projects Increase collaboration between all state payer and providers Streamline Point of Service functions (e.g., Smart Cards) Fully develop e-prescribing functionality 2. Simplified interaction with the Health Care infrastructure for providers Credentialing Web-based Access Enhanced Technology Supports 3. Improved Health Care Outcomes measured by increased usage of performance criteria Create clear outcomes and expectations for providers to address pay for performance and quality of care Incentivize providers to use quality preventative care Utilizing HIE/HIT to improve health care Quality and Safety. Develop and expand innovative approaches to prevention. Develop a comprehensive statistical profile for delivery and utilization patterns 4. Evolving use of modern information technology to improve the delivery of health care and outcomes, identify administrative efficiencies, coordination, and optimization of care Administrative Efficiencies- Coordination of Care 5. Integrated medical service delivery model that includes high quality Medicaid providers Encourage and promote retention of quality Medicaid providers Explore health care literacy program to reduce Emergency Room use by Medicaid population Implement Statewide HIE to improve episode of care management Improve eligibility coordination and knowledge sharing between agencies and business partners 6. Move from client focus to family or community based health care Development of strong Medical Home model delivery system Page 39 of 81

40 Components Projects 7. Public Health Centralized ISDH Meaningful Use (MU) Hub MU Website MU Data Portal Real-time Bidirectional Interface for CHIRP Data Encryption Implementation and Security Scan 8. Technical Assistance (TA) for Providers through REC-like services 90/10 funding for Purdue Health Authority to continue technical assistance (TA) and outreach for providers interested in EHR adoption, Meaningful Use, Interoperability and HIE participation C.3 Public Health Health Information Technology Strategy ISDH plans to leverage Meaningful Use EPs and EHs as the primary groups for improving the quality, safety, and health of citizens of Indiana. To meet the objectives, ISDH and FSSA have identified the following list of projects to streamline and improve data collection and quality to support population health: Centralized ISDH Meaningful Use Hub (MU Data Hub) design, develop, and implement a supporting end user support and system/data interaction o MU User Support Website: public health meaningful use registration, training, and guidance for public health reporting measures o ISDH MU Data Portal (DP): electronic system providing quality assurance testing for accurate MU data to IDSH registries (Cancer, ELR, Syndromic Surveillance, and Immunization [MyVax]) o ISDH MU Data Portal (DP) Automated Feedback Tools: alert system to assess quality of data message for planning, data feed and quality discrepancies, and support ticket generation for ongoing tracking and monitoring of issues. State Immunization Information System (CHIRP) Bidirectional Interfaces (Real-time Bidirectional Immunization Interfaces) improve bidirectional connections for data submission and retrieval from EPs, EHs and CAHs and timeliness of immunization data flow o Bidirectional Immunization Data Submission and Retrieval by EPs, EHs, and CAHs: continue to connect and bi-directionally submit and receive immunization forecasts and histories to/from the Immunization Information System (IIS) and to/from EPs, EHs, and CAHs o Real-time Bidirectional Immunization Data Flow: improve timeliness of querying IIS for stored immunization messages, moving from batch processes via nightly deduplication process taking hours to near real-time ISDH MU Data Encryption Audit and Security Scan (Security Scan) review and conduct a series of internal and external security scan and identify count measures for any security gaps for data transmission and storage Meaningful Use Training and Outreach (MU Training) provide Public Health reporting Meaningful use attestation support for providers and facilities in cooperation with other MU technical assistant partners. Page 40 of 81

41 o o o Outreach Plan: Develop outreach and support plan for ISDH Cancer Registry data submissions Cancer Registry Guidelines: Increase Cancer Registry data submissions from more facilities Training Material: Develop Public Health MU Training material to streamline and facilitate public health data reporting attestation requirements in cooperation with other MU TA partners Figure 6. Outside ISDH Electronic Data Flow Page 41 of 81

42 D. Activities Necessary to Administer and Oversee the EHR Incentive Program This section includes a description of the business processes OMPP will employ to ensure that eligible professionals (EP) and eligible hospitals (EH) including Critical Access Hospitals (CAH) have met Federal and State statutory requirements to receive incentive payments in the EHR Incentive Program. OMPP plans to use their standard MITA business processes where feasible, and integrate the Indiana EHR Incentive Program into day-to-day operations in partnership with Hewlett Packard (HP) where appropriate. Examples of new state-specific business processes to be developed include: Provider registration Provider eligibility determination and verification Medicaid patient volume verification Provider attestation verification Adopt, Implement or Upgrade (AIU) and Meaningful Use (MU) Query to the Medicare and Medicaid EHR Incentive Program Registration & Attestation System (R&A) D.1 Concept of Operation and Administration OMPP administers the Indiana Medicaid EHR Incentive Program using resources located in the HIT Unit within FSSA s Division of Healthcare Strategies and Technologies. The HIT Coordinator is responsible for developing operational policies and procedures for the EHR Incentive Program, researching regulatory questions as they arise, and completing additional activities to plan, coordinate and update the SMHP and IAPD and oversight of the preand post-payment activities. The HIT Coordinator is responsible for overall coordination of program, oversight and supervision of HP for pre-payment activities and Myers and Stauffer LC for post-payment activities. The HP staff is responsible for performing provider enrollment, customer service, help desk support and maintenance of the EHR Incentive Program system. In addition, HP supports the review and approval of requests received from the Medicare & Medicaid EHR Incentive Program Registration & Attestation System (R&A), monthly payment processing and required EHR Incentive payment reporting. In its role as program administrator, the HIT Coordinator also coordinates provider outreach with Purdue Health Authority (PHA) which provides technical services to eligible professionals, hospitals, and CAHs enrolling in the Indiana Medicaid EHR Incentive Program. The OMPP leverages existing Medicaid business processes to manage the program including provider enrollment, provider payment process, provider audits and state and federal reporting. D.2 Audit Work Group The Indiana Health Information Technology EHR Incentive Program FSSA Audit Work Group, having successfully produced the Indiana HIT FSSA Audit Plan no longer meets on a regular basis; however, the HIT Coordinator meets with the FSSA audit staff on a regular basis in between active audit periods. In addition, during active audit periods, the HIT Coordinator meets with the FSSA audit team once a week to discuss any issues. The FSSA audit staff generates weekly reports that are shared with the HIT Coordinator. Myers and Stauffer, LC is Page 42 of 81

43 the third-party auditor for the Indiana EHR Incentive Program and meets regularly with FSSA on past, current and future audits as well as updates to the Audit Plan required annually by CMS for the EHR Incentive Program. D.3 Technology Work Group The Technology Work Group assisted in identification of system requirements and development and planning for the ongoing EHR Incentive Program systems updates. Having successfully procured and implemented the Indiana R&A, he Technology Work Group is no longer necessary. The HIT Coordinator regularly communicates with HP regarding the Medical Assistance Provider Incentive Repository (MAPIR) system and is responsible for the review of data standard needs and further exploration of issues like integration of the MMIS to the larger statewide HIE initiatives. The HIT Coordinator meets regularly with the FSSA staff responsible for the Medicaid Enterprise systems. D.4 Clinical Quality Work Group Early in the program development process, OMPP Quality Staff participated in an intensive work session to consider how EHR meaningful use reporting requirements and the development of expanded clinical data capture and reporting by EP, EH and CAH using certified EHR technology would impact OMPP s objectives for clinical quality measurement and reporting. An initial informal Clinical Quality Work Group was formed of medical, clinical, quality, and audit staff formed to discuss legislation, review data, make recommendations, and provides direction on clinical and quality assurance issues and measures related to this program. Currently, there are no plans to formally institute a Clinical Quality Work Group, but as HIT, HIE, and interoperability continue to advance in Indiana, the HIT Coordinator will re-examine the impacts of the first phase of the Program, consider the implications of expanded capacity for clinical data reporting among Medicaid programs and the HIOs, and formulate a strategy for collecting, analyzing and making full use of Clinical Quality Measures (CQM) and other meaningful use measures. D.5 Provider Communications The HIT Coordinator, in partnership with PHA as the REC and primary responsible entity for outreach to EPs, EHs and CAHs, communicates prior, during, and after each attestation program year. PHA performs all outreach on attestation and eligibility requirements as well as education on Meaningful Use using newsletters, webinars and direct outreach. HP, the current MMIS Fiscal Agent Vendor, has many communication requirements and touch points currently used with regards to communicating within FSSA and OMPP, as well as communicating with Providers and other external entities. D.5.1. External Surveys External surveys, including those performed for this latest version of the SMHP (see Section B13), have been performed. In 2015, PHA performed a provider satisfaction survey. Survey 1: Indiana EHR Incentive Program - Medicaid Providers Satisfaction Survey: In 2015, Purdue Health Authority (PHA) conducted a provider satisfaction survey in order to assess the satisfaction of Page 43 of 81

44 providers participating in the Indiana Medicaid EHR Incentive Program. The survey consisted of 14 questions and was sent to 591 contacts from the MAPIR system. By the close of the survey period, the response rate was 12% with 70 organizations fully completing the survey. In summary, 74% of the respondents were either very likely or likely to continuing to attest for Meaningful Use and 77% of respondents were satisfied with the help they received when they contacted customer service either via or phone. Survey 2: Indiana EHR Incentive Program AIU-only Medicaid Providers Survey: In addition to the Medicaid Provider Satisfaction Survey, PHA conducted a survey for AIU-only providers in the Indiana EHR Incentive Program. The 7-question survey was conducted to assess the reasons providers participating in the EHR Incentive Program completed AIU but have not yet attested to Meaningful Use. The survey was sent to 201 EPs and had 35 responses for a 17% response rate. One hundred percent (100%) of respondents indicated that they were still using their EHR and 83% planned on attesting to Meaningful Use. When asked about the biggest challenge with the adoption of an EHR, several respondents indicated that poor reporting capability, incorrect data, and problems with the patient portal for their chosen EHR were their biggest barriers. D.5.2. Publications Bulletins, Banners, Newsletters, Letters, and Website: OMPP and HP utilize multiple media outlets such as bulletins, banners, newsletters, letters, and the websites (e.g. and to communicate HIT EHR relevant-information with the Provider Community during the life of the Indiana EHR Incentive Program project. The bulletins, banners, newsletters, and any website documentation will be referenced to the applicable website if a web posting or if a non-web posting, the communication will be posted on the OMPP HIT SharePoint site by the HIT Coordinator. D.5.3. Program Process Audits Internal Audits: OMPP is required to participate in an In-Office Review Audit conducted by FSSA Audit Services Team and the Indiana State Board of Accounts and/or upon request by CMS. All audits require HIT EHR Project Team Member commitment and participation at various stages of the audit process. From the preparation work, to mock-audit activities, to documentation preparation, report creation, etc., all auditrelated communications, documentation, and the work products created are critical to the success of the audit. All audit findings will be posted in a secured area on the OMPP HIT SharePoint site by the HIT Coordinator and/or the FSSA Audit Services Team members or their appointed designee(s). D.6 Recent Changes in State Laws and Regulations At this time, no state laws or regulations have been identified that will impact the continued operation of the Program. Although the governor established the Indiana Health Information Technology, Inc. (IHIT), to provide strong oversight, the IHIT operated under a governance model that combined private sector electronic HIE with strong state direction and multi-stakeholder collaboration. To date, this process has enabled Indiana to move toward the necessary support of meaningful use through the efforts of the four exchange networks that currently operate within Indiana without the need for new state laws or regulations. Page 44 of 81

45 At this time, no state laws or regulations have been identified that will impact the implementation of the Indiana EHR Incentive Program, and no new laws are currently anticipated as a result; however, 2016 is an election year and many senior position across the government may change which may result in a slight shift on HIT strategies. D.7 Policy Changes Early in the initial implementation of the EHR Incentive Program in Indiana, it was determined that Indiana would need to address the issue of enrolling Physician Assistants (PA) within the MMIS program. CFR specifies an FQHC or RHC must be PA led in order for PAs to qualify for incentive payments as an eligible professional. If an Indiana Medicaid enrolled FQHC or RHC becomes PA led, and that PA meets all program, eligibility and patient volume requirements of an eligible professional, Medicaid will assist the PA with enrollment in the EHR Incentive Program. To address this issue PAs are now enrolled within MMIS, thus ensuring capability to make appropriate incentive payments to all eligible EPs. So far, Indiana has only enrolled one PA that was confirmed as meeting the requirement for so led. In the future, prior to enrolling a PA in the MMIS, Medicaid will determine whether the PA leads an FQHC or RHC by checking with the Indiana Primary Health Care Association (IPHCA), the clinic s web site and/or the Indiana State Office of Rural Health Programs. As regulations from CMS are issued, policies are updated to reflect the changes. Examples of these changes which have been incorporated into the SMHP include changes to the final Stage 2 Meaningful Use regulations, the 2014 Flexibility rule and the Modified Stage 2 rule. As the HIT Coordinator further refines the program operations to meet the Meaningful Use requirements, policy changes may be required and will be addressed according to existing program policy maintenance procedures as needed. These policy updates, should they be required, will be reported in a subsequent iteration of the SMHP. D.7.1 Modification to Meaningful Use in SMHP Addendum On October 16, 2015, CMS published a Final Rule, Medicare and Medicaid Programs; Electronic Health Record Incentive Program Stage 3 and Modifications to Meaningful Use in 2015 through 2017 to the Federal Register, or the Modifications Rule. The changes specified in the Modifications Rule were effective on December 15, Indiana completed a comprehensive analysis of the Modifications Rule and the following tables outline the changes to Meaningful Use (MU) and the EHR Incentive Program that Indiana plans to incorporate starting in Program Year 2015 for Eligible Professionals (EP) and Eligible Hospitals (EH) respectively. This addendum was submitted to and approved by CMS in April 2016 and the approved changes are in the tables below. Table 6. Eligible Professionals (EP) Modifications to Meaningful Use Eligible Professionals (EP) Modifications to Meaningful Use (MU) Change 90-day reporting period for 2015 Explanation First time and returning EPs attesting to MU will choose any continuous 90-day period in calendar year 2015 for their EHR reporting period. Effective Program Year 2015 Page 45 of 81

46 Eligible Professionals (EP) Modifications to Meaningful Use (MU) Change 90-day reporting period for 2016 Full year reporting period for day reporting period for 2017 Full year reporting period for 2017 Remove the differentiation between MU Core and Menu objectives Stage 1 specifications for EPs in 2015; lower thresholds and exclusions Modified Stage 2 MU objectives in 2016 and Edition Certified Electronic Health Record Technology (CEHRT) CEHRT Edition(s) in 2017 MU required measures for Explanation EPs attesting to MU for the first time in 2016 will choose any continuous 90-day period in calendar year 2016 for their EHR reporting period. Returning EPs attesting to MU in 2016 will use the full calendar year 2016 for their EHR reporting period. EPs attesting to MU for the first time in 2017 will choose any continuous 90-day period in calendar year 2017 for their EHR reporting period. EPs attesting to Stage 3 MU for the first time in 2017 only will choose any continuous 90-day period in calendar year 2017 for their EHR reporting period. Returning EPs attesting to Stage 2 MU in 2017 will use the full calendar year 2017 for their EHR reporting period. Starting in 2015, all MU objectives will be required and will be considered Core objectives. EPs scheduled to demonstrate Stage 1 MU in 2015 will be required to report to the Stage 2 MU objectives for all consolidated objectives. EPs will report on Stage 1 MU specifications for objectives that have a lower threshold in Stage 1 MU than Stage 2 MU. Exclusions for objectives that do not have an equivalent Stage 2 MU objective are available. If an EP is scheduled to demonstrate Stage 1 MU in 2015 but can attest to the Stage 2 MU threshold on an objective, he/she may choose to do so. All EPs will attest to the modified, consolidated Stage 2 MU objectives in 2016 and 2017, regardless of stage in 2015, including Adopt, Implement or Upgrade (AIU). A 2014 Edition CEHRT is required for all attestations, AIU or MU, in program years 2015 and EPs may use either a 2014 Edition, 2014/2015 Edition combination, or 2015 Edition CEHRT for MU attestations in program year The 10 modified MU measures for EPs in include: 1. Protect Patient Health Information 2. Clinical Decision Support 3. Computerized Physician Order Entry (CPOE) 4. Electronic Prescribing Effective Program Year Page 46 of 81

47 Eligible Professionals (EP) Modifications to Meaningful Use (MU) Change Discontinued MU measures 2015-Forward Explanation 5. Health Information Exchange 6. Patient Specific Health Education 7. Medication Reconciliation 8. Patient Electronic Access a. Measure 2 remove 5% threshold for 2015 and 2016 and require that at least one (1) patient (or authorized representative) seen by the EP views, downloads, or transmits their health information to a third party. b. Measure 2 in 2017, the threshold returns to 5% of all unique patients (or authorized representative) seen by the EP views, downloads, or transmits their health information to a third party. 9. Secure Electronic Messaging a. In 2015, the capability for patients to send a secure electronic message with the EP is fully enabled in the CEHRT. b. In 2016, at least one (1) patient seen by the EP during the EHR reporting period, a secure message was sent using the electronic messaging function of the CEHRT. c. In 2017, at least 5% of unique patients seen by the EP sent a secure message using the electronic messaging function of the CEHRT. 10. Public Health Reporting The MU measures discontinued starting in program year 2015 and moving forward through the program include: 1. Record Demographics 2. Record Vital Signs 3. Record Smoking Status 4. Clinical Summaries 5. Structured Lab Results 6. Patient Lists 7. Patient Reminders 8. Summary of Care a. Measure 1 Any method b. Measure 3 Test 9. Electronic Notes 10. Imaging Results 11. Family Health History Effective Program Year Page 47 of 81

48 Table 7. Eligible Hospitals (EH) Modifications to Meaningful Use Eligible Hospitals (EH) Modifications to Meaningful Use (MU) Change 90-day reporting period for day reporting period for 2016 Full year reporting period for day reporting period for 2017 Full year reporting period for 2017 Remove the differentiation between MU Core and Menu objectives Stage 1 specifications for EPs in 2015; lower thresholds and exclusions Modified Stage 2 MU objectives in 2016 and Edition Certified Electronic Health Record Technology (CEHRT) CEHRT Edition(s) in 2017 MU required measures for Explanation First time and returning EHs attesting to MU will choose any continuous 90-day period in calendar year 2015 for their EHR reporting period. EHs attesting to MU for the first time in 2016 will choose any continuous 90-day period in calendar year 2016 for their EHR reporting period. Returning EHs attesting to MU in 2016 will use the full calendar year 2016 for their EHR reporting period. EHs attesting to MU for the first time in 2017 will choose any continuous 90-day period in calendar year 2017 for their EHR reporting period. EHs attesting to Stage 3 MU for the first time in 2017 only will choose any continuous 90-day period in calendar year 2017 for their EHR reporting period. Returning EHs attesting to Stage 2 MU in 2017 will use the full calendar year 2017 for their EHR reporting period. Starting in 2015, all MU objectives will be required and will be considered Core objectives. EHs scheduled to demonstrate Stage 1 MU in 2015 will be required to report to the Stage 2 MU objectives for all consolidated objectives. EPs will report on Stage 1 MU specifications for objectives that have a lower threshold in Stage 1 MU than Stage 2 MU. Exclusions for objectives that do not have an equivalent Stage 2 MU objective are available. If an EH is scheduled to demonstrate Stage 1 MU in 2015 but can attest to the Stage 2 MU threshold on an objective, the EH may choose to do so. All EHs will attest to the modified, consolidated Stage 2 MU objectives in 2016 and 2017, regardless of stage in 2015, including Adopt, Implement or Upgrade (AIU). A 2014 Edition CEHRT is required for all attestations, AIU or MU, in program years 2015 and EHs may use either a 2014 Edition, 2014/2015 Edition combination, or 2015 Edition CEHRT for MU attestations in program year The nine (9) modified MU measures for EHs in include: Effective Program Year Page 48 of 81

49 Eligible Hospitals (EH) Modifications to Meaningful Use (MU) Change Discontinued MU measures 2015-Forward Explanation 1. Protect Patient Health Information 2. Clinical Decision Support 3. Computerized Physician Order Entry (CPOE) 4. Electronic Prescribing 5. Health Information Exchange 6. Patient Specific Health Education 7. Medication Reconciliation 8. Patient Electronic Access a. Measure 2 remove 5% threshold for 2015 and 2016 and require that at least one (1) patient (or authorized representative) discharged from the EH s inpatient (POS21) or emergency department (POS23) views, downloads, or transmits their health information to a third party. b. Measure 2 in 2017, the threshold returns to 5% of all unique patients (or authorized representative) discharged from the EH s inpatient (POS21) or emergency department (POS23) views, downloads, or transmits their health information to a third party. 9. Public Health Reporting The MU measures discontinued starting in program year 2015 and moving forward through the program include: 1. Record Vital Signs 2. Record Smoking Status 3. Structured Lab Results 4. Patient Lists 5. Summary of Care a. Measure 1 Any method b. Measure 3 Test 6. Electronic Notes 7. Imaging Results 8. Family Health History 9. emar 10. Structured Labs to Ambulatory Providers 11. Advanced Directives Effective Program Year Page 49 of 81

50 D.8 HIE/HIT Activities across State Borders Currently providers from Illinois, Ohio, Michigan, and Kentucky can be enrolled as Indiana Medicaid providers and Indiana Medicaid receives data from these providers. This exchange of information allows Indiana providers who are relying on patients from one of our border state s Medicaid programs to meet volumes for EHR Incentive Program eligibility. Additionally, the surrounding states will have access to Indiana Medicaid eligibility and patient volume information to verify corresponding data for providers relying on Indiana information for their EHR Incentive Programs. Since Indiana has HIOs that span state lines, Medicaid works through the HIOs and uses the HIOs relationships to foster interstate health information data exchange. OMPP will reevaluate the need for these agreements in the future should this information become available through the national HIE infrastructure. D.9 Privacy Regulatory Changes On an ongoing basis, FSSA and OMPP ensures the State s HIT and HIE efforts, including the EHR Incentive Program, are aligned and fostering stakeholder compliance with appropriate state and federal privacy and security provisions and industry standards. Early in 2013 final omnibus amendments (the 2013 Amendments) to the Privacy, Security, Breach Notification and Enforcement Rules of the Health Information Portability and Accountability Act (the HIPAA rules) were issued, as directed by the HITECH Act of The 2013 Amendments include a number of sweeping changes with implications for entities that transmit and analyze health care data. Key provisions expand the definition of a business associate and establish a higher threshold for determining whether a breach occurred. OMPP is working to assess its internal operations. The HIT Coordinator and IHIT are working with the HIOs and the State s RECs to ensure that providers, organizations and information sharing partners are aware of their added responsibilities, and that they revisit their Business Associate Agreement and overall contracting and business processes to ensure compliance with new privacy and security provisions. D.10 Provider Contract Changes At the time of enrollment all new IHCP providers are required to execute a provider agreement with OMPP. This agreement addresses the exchange of information, including health information, between the provider and the Medicaid Agency. It also addresses the requirements for providers to comply with all federal and state statutes and regulations, to fully cooperate with federal and state officials in the conduct of inspections, reviews and audits, and to make full reimbursement of any disallowances related to payments previously made. In addition it includes providers appeal rights and responsibilities. D.11 Provider Eligibility Determination To be eligible for the Indiana EHR Incentive Program, a professional must be enrolled in the MMIS as a traditional Medicaid provider and meet certain Medicaid patient volume requirements. When the EP, EH, or CAH has completed registration in the Medicare & Medicaid EHR Incentive Program R&A System, the provider will be instructed on how to register and attest using Indiana s provider incentive payment system, MAPIR, which is integrated into Indiana s existing provider web portal. Providers will be able to log on to Page 50 of 81

51 the provider portal and complete registration and attest to AIU and patient volume during their first program year. Initially providers submitted via fax additional information needed to complete the attestation; MAPIR functionality has been subsequently deployed that enables providers to submit all of this information electronically. Web InterChange is an interactive Web application that allows providers to access the IHCP computer system through the Internet. Web InterChange is fast, reliable, secure, free, and does not require providers to obtain or use special software. The product is well known to the Indiana Medicaid Providers who currently use the web site to submit claims, view claims status online, review remittance advice, request prior authorization, inquire about checks, maintain provider profile and demographics, and verify member eligibility and review provider education materials and obtain program manuals for all Indiana Health Care Programs. The Web InterChange serves as the gateway and using their Web InterChange sign-in, providers easily link to the EHR Provider Incentive Payment system to enter EHR enrollment and attestation information. EPs and EHs log on to Indiana s existing provider portal using their valid provider identification number (ID) to register. After entering the CMS Registration Number and receiving confirmation of Medicare & Medicaid EHR Incentive Program Registration & Attestation System (R&A) registration, within the portal the system validates eligibility of the provider s enrolled type as well as the NPI/TIN (National Provider Identifier/Taxpayer Identification Number) combination. The following process flowcharts (Figure 7, below and next page) show the high level process that eligible providers and hospitals go through to enroll in Indiana s Medicaid EHR Incentive Program. Figure 7. EP and EH Registration and Attestation Processes Page 51 of 81

52 When the EHR Incentive Payment system receives a transaction from the Medicare & Medicaid EHR Incentive Program R&A indicating that a provider has registered for the Indiana EHR Incentive Program, a transaction is stored in a database in the MMIS for record tracking. Two basic validations are made: 1) validate the provider is currently enrolled as an Indiana Medicaid provider; and 2) validate the provider is an eligible professional or eligible hospital. If these conditions are not met, a provider not eligible status is automatically sent back to the Medicare & Medicaid EHR Incentive Program R&A. Indiana has incorporated the following features for the Indiana EHR Incentive Program web site: 1. Instructions on the EHR Provider Enrollment Process 2. How to correct registration error with the Medicare & Medicaid EHR Incentive Program R&A 3. How to calculate patient threshold 4. How to assign payment to a third party and OMPP verifications of information provided 5. How to request an appeal for a provider enrollment or payment decision 6. Information and links to CMS EHR Incentive Program web site and Fact Sheets 7. Goals and objectives of EHR Incentive Program The OMPP contractor verifies provider eligibility for the EHR Incentive Program and updates the EHR Incentive Payment system accordingly. This triggers a registration eligibility response transaction (B-7) update to the Medicare & Medicaid EHR Incentive Program R&A. In addition, when eligibility and all supporting documentation has been received and verified a duplicate payment inquiry is sent to the Medicare & Medicaid EHR Incentive Program R&A. Components of the provider eligibility processing include: Attestation Verification: The EP must enter the numerator and denominator for patient volume (e.g., Page 52 of 81