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1 Centers for Medicare & Medicaid Services: Medicaid Electronic Health Records Incentive Program for Eligible Professionals: Conference Call: Moderator: Diane Maupai: February 18, 2011: 1:00 p.m. ET: Welcome:... 2: Presentation slides 1 through 24:... 3: Presentation Slides 25 through 45:... 12: Question and Answer Session:... 17: Question and Answer Session continued:... 30: Page 1

2 Welcome Welcome to the Medicaid Electronic Health Records Incentive Program for Eligible Professionals Conference Call. All lines will remain in a listen-only mode until the question and answer session. Today s conference call is being recorded and transcribed. If anyone has any objections you may disconnect at this time. Thank you for participating in today s call. I will now turn the conference over to Ms. Diane Maupai. Ms. Maupai, you may begin. Diane Maupai: Good afternoon, everyone. My name is Diane Maupai; I m with the Provider Communications Group in CMS in Baltimore. I m glad you can join us today. Let me start by apologizing for the problems we ve had with getting you the presentation material. We ve had some systems issues in CMS this week, so we weren t able to post them as we had hoped. You should have received the presentation in an earlier today but in case you haven t seen it the sender is medicare.ttt@palmettogba and the subject line is Presentation for Registration for the Medicaid EHR Incentive Program for Eligible Professionals. I hope you find it there and I hope you have it. But in case there are a couple of people that don t; I m going to read a link that contains the presentation and you have to forgive me because it s a mouthful. It s ning.pdf and we will be posting the slide deck on the CMS Page after the call. I m sure the issues we have will be resolved. So moving onto content. Here at CMS we re really excited that the first 11 States have launched their Medicaid EHR Incentive Program on January 3rd. We re looking forward to other States launching during the spring and the summer. If you d like to know when your State s program will open for registration, please contact your State Medicaid agency or go to the Medicaid State Information Page on the CMS Website that is Page 2

3 Now I m happy to introduce our speaker for today. Michelle Mills is the Technical Director in the Centers for Medicaid, CHIP and Survey and Certification. Thank you, Diane. I m really excited to talk to folks today about registering for the Medicaid EHR Incentive Program here at CMS. Yesterday was the second anniversary of the Recovery Act, which contained all of the provisions in the HITECH Act, which authorized this program. As of today, we have almost 4,000 eligible professionals in 11 States that have initiated registration for this program. We have almost 600 hospitals in 47 States that have initiated registration for both the Medicare and Medicaid program. The Medicaid EHR Incentive Program payments to eligible professionals at this time, is almost $1.75 million. That s to 82 eligible professionals in four different States. The Medicaid EHR Incentive payments to hospitals reached almost $30 million and that s again in the first six weeks of the program that s going to 20 eligible hospitals in three States. So with that, I m going to go ahead and start the presentation. We will save time for questions and answers at the end of the call. Presentation slides 1 through 24 We re going to cover some basics for level setting today about program eligibility in both Medicare and Medicaid for hospitals; eligible professionals and Critical Access Hospitals and then we re going to get more into the registration details and eligibility verification. The reason we are going to touch on Medicare a little bit is because we ve heard in our research here with external affairs that some providers are still confused about whether they re eligible for Medicare or Medicaid or both and how that works and just understanding the basics of both programs and the eligibility requirement. So with that I m on the third slide that has the Venn diagram and this includes eligible professionals for both programs. So the eligible professionals here in the middle are Doctors of Medicine, Doctors of Osteopathy or Doctors of Dental Medicine or Surgery. They are eligible for both the Medicare and the Medicaid EHR incentives so long as they meet all of the other program requirements. Page 3

4 Furthermore the providers listed on the right, the Nurse Practitioners, Certified nurse midwives, and Physician assistants in certain circumstances are eligible for the Medicaid EHR incentives but not the Medicare EHR incentives. Doctors of Optometry, Podiatric Medicine, and Chiropractors generally can only participate in Medicare and you can see those there on the left. Moving to the next slide similar for hospitals, we expect most hospitals in this program to be eligible for both Medicare and Medicaid. Unlike the eligible professionals, hospitals that are eligible for both Medicare and Medicaid can receive incentives for both programs. So again, to underscore that it s important, Medicare and Medicaid eligible professionals, the slide we just looked at, they have to pick between Medicare and Medicaid. Hospitals who are eligible for both may receive an incentive under both programs. The subsection(d) hospitals and Critical Access Hospitals, which are also typically acute care hospitals under Medicaid all fall into this category of meeting the requirements for both so long as they have at least 10 percent of their patient volume coming from Medicaid. Additionally, Children s hospitals, acute care hospitals in the territories and Cancer hospitals will all be eligible for the Medicaid incentive, but not Medicare. Moving to the next slide some basics about the Medicaid eligibility for this program, so as we mentioned on a previous slide you must be one of five types of eligible professionals so that was again the Physicians, the Certified nurse midwives, Nurse Practitioners, Dentists or Physician assistants when they practice in certain locations. You can participate if you re one of those five eligible professional types, if you either have at least 30 percent of your patient volume derived from Medicaid or you practice predominantly in a Federally Qualified Health Center or a Rural Health Clinic where you have at least 30 percent of your patients coming from what we consider to be needy individuals. Needy individuals typically are Medicaid, CHIP, or individuals receiving services free or on a sliding scale based on income. Additionally, there is one more caveat for pediatricians; in order to help facilitate pediatricians participation in this program, they have a decreased patient volume threshold so pediatricians can participate in this program if Page 4

5 they have at least 20 percent Medicaid patient volume, whereas that would be 30 percent for the other provider types. If pediatricians participate at this reduced patient volume threshold their incentive is also reduced, which we ll talk about later. That provision doesn t apply for practicing predominantly in the FQHC or the RHC and it doesn t apply to the other eligible professionals. Pediatricians are regular physicians so of course if they have higher than 30 percent Medicaid patient volume they can participate at a full incentive as well. Furthermore, all eligible professionals must be licensed and credentialed appropriately in one of those five eligible professional types. You can t have any Office of the Inspector General exclusions which are it s the Federal exclusion list that would prohibit you from receiving Medicaid money. And you must also be living in other words not on the Social Security s Death Master File and you must not be hospital-based. Hospital-based means that you have more than 90 percent of your professional services being provided in either the inpatient or the emergency department settings of a hospital. So more about Medicaid basics, we re going onto the next slide. An Acute care hospital must also have at least 10 percent Medicaid patient volume in order to participate. For Medicaid an acute care hospitals is a general short term stay hospital that includes the 11 Cancer hospitals and Critical Access Hospitals as well. We define the general short-term stay hospital as a hospital with an average length of stay of 25 days or fewer. The CMS certification number also known as the OSCAR number or the provider number must end in 0001 to Those are the same that s the same range typically for subsection(d) hospitals. It s important to note that, for example, the Cancer hospitals while they fall in that range, they are not eligible for the Medicare incentive, which we ll discuss here in a couple of slides. And finally, Children s hospitals have no patient volume thresholds. They have at least half of their patient volume threshold coming from Medicaid anyway, but that requirement was not placed on them per the statute. Going to the next slide and talking about some Medicare basics, as we mentioned earlier, you must be a physician to participate in the Medicare Page 5

6 program. The definition of physician as we noted on that first slide with the Venn Diagram, the physician definition is different between Medicare and Medicaid so in order to participate for Medicare you can be an MD, a DO, a Doctor of Dental Medicine or Dental Surgery, an optometrist, a podiatrist or a chiropractor. All of those types are considered a physician under the Medicare program and that s consistent with our program here. Additionally, in order to get an incentive you must have Part B Medicare allowed charges. We know sometimes people meet the other requirements for the program, but they don t have any Part B Medicare allowed charges. Additionally, just like Medicaid, they can t be hospital-based to participate and they must be also enrolled in our Provider Enrollment, Chain and Ownership System also known as PECOS, which is the system that we pay providers under for Medicare and just like Medicaid they have to be living and not on the OIG exclusions list. Moving to the next slide for Medicare hospitals, as we mentioned, the hospitals for Medicare must be subsection(d) hospitals for Medicare. These are typically the acute care hospitals that are paid on the inpatient prospective payment system for Medicare. They must also be in the 50 United States or in D.C. so that s why the hospitals in the territories aren t qualified for this provision under Medicare. They could get Medicaid hospital incentives, but not Medicare. Additionally, Critical Access Hospitals are eligible for both programs as well.. Moving to the next slide, so in order to register for this program, all providers whether they re hospital Medicare, Medicaid, eligible professional, need an NPPES web user account; NPPES is the system of enumeration that we use here at CMS for the National Provider Identifier (NPI), having an application in and an NPI generally does not mean you have a web user account. We re using that web user account login information in order to log in for this program to make it easier on providers so that is necessary that they have a web user account prior to coming in to registering. If you don t have one now you should go get one. Page 6

7 Medicare EPs and all hospitals must also have a current enrollment record in PECOS the way this impacts Medicaid providers; not Medicaid EPs, but Medicaid hospitals, is that they have to have a current enrollment record in PECOS. So they could check with us if they have questions about whether they have a current enrollment record in PECOS or they can call the contractor and ask questions. Moving to the next slide, in order to get a payment, Medicare EPs and hospitals must have Meaningfully Used certified EHR technology, Meaningful Use has been one of those things has been a big part of this program and so we re not going to get into that today because we re talking about Medicaid EPs and hospital registration, but we will talk a little bit about certified EHR Technology. Also, Medicare EPs and hospitals have to attest to all the program requirements, the Meaningful Use requirements and get an EHR Certification Number from the CHPL which we ll talk about later in this presentation as well. Slightly different Medicaid eligible professionals and hospitals don t have to demonstrate Meaningful Use in the first year of participation. So again Medicaid eligible professionals and hospitals don t have to demonstrate Meaningful Use in their first year of participation to get an incentive. Instead, they can show that they adopted, implemented, upgraded or meaningfully used certified EHR technology. These adopted, implement and update requirements are much easier to meet than the Meaningful Use requirement and the intent is to offset the costs associated with getting the EHR technology in order to eventually meaningful use. The Medicaid EPs and hospitals must also attest to all of the other program requirements and we ll talk more about that later too. So those are the program basics, hopefully it was some good level setting for everyone and now we re ready to register, so what s next? So you ll see a very an image on the next slide of a very complicated contraption. This is what we tried to avoid while we were setting up our Page 7

8 system. I want folks to keep in mind that we re going to go through a lot of caveats and exceptions and make it sound like this is what we put out but we are administering a program that will ultimately give out $30 billion in incentives for this program. Those are estimates over a 10 year period and we there are some different checks and balances in place to make sure that we re giving the right amount of money to the right providers. So with that on the next slide, we tried to cut through as much red tape as possible to make this program easy to use for providers so they can register, attest, and get paid. So moving to the first slide, talking about registering, attesting and getting paid for Medicaid; States with launched programs--so those are the 11 States that Diane mentioned at the beginning of this presentation, the EPs and hospitals can go to the CMS EHR Incentive Program Website, click on the Registration Tab and complete the registration. Again, when you get there, you ll need your NPPES or NPI web user account login information to access the system. After you complete all of the registration information at the CMS site, you need to go your State s website and complete the eligibility verification. We re going to go through this in a little bit more detail later but the States will ask you questions about your patient volume and whether you have been sanctioned and how you re licensed and so on. Then after that States will pay you no later than five months after you register; most are paying sooner. Kentucky and Oklahoma, two of our first States to launch their program, paid providers in that first week. Kentucky saw two hospitals receive payments totally approximately $5 million on that first Wednesday after we launched the program and Oklahoma paid a group practice in Oklahoma as well for two eligible professionals at that practice. So moving to the next slide, you can see what the first page looks like of the CMS Registration and Attestation System. This is the first when you go to that page, this is the first thing you ll see. You aren t yet asked for your login information, gives you some general information about the site, additional resources, you ll see throughout the site, we refer you back to the CMS Page 8

9 Website if you have any questions. Hopefully, your questions can be answered there. There s a drop down menu both for eligible hospitals and eligible professionals here that show you more information about what it means to be one of those in one of those categories. Moving to the next slide, this is the first login page. This is where we mentioned that you ll use your NPI web user account information and password to log into the system. It is not appropriate to share that information with other individuals in order to register on your behalf. At the end of this, these slides will show you the one where you re attesting to providing sure and accurate legal information under your name. If somebody does that on your behalf, you re still liable legally for everything that is contained in this document. Moving to the next slide, this shows you the tabs that will guide you through each part of the registration process. The Attestation Tab is not relevant for the Medicaid eligible professionals, so you won t need to use the attestation tab. That will be for the Medicare eligible professional and hospitals, and hospitals that are dually eligible for both Medicare and Medicaid. The Status Tab will tell you throughout the process where you are. So if your registration file is sent to the State for validation or eligibility verification it will say that in the Status Tab. If you re expecting to receive a payment, it will say that you re payment is being processed so that s a good place to always check in this program to see where you are in the process. Finally, the Account Management tab allows you to do some higher level administrative management. The next slide shows you the registration instruction screen. This is the next thing you would see after you login. It gives you some general information about different actions that can take place. So of course you can register, you can modify a registration, you can cancel a registration if you decide you did not want to be considered to this program; however, it s worth noting that if you come in and register and you don t cancel your program, your Page 9

10 information will be sent to the State and could still receive a payment. So if you ve accidentally provided information that was incorrect you would need to go back and either modify or cancel your registration. You can reactivate a registration after it s been cancelled and finally you can resubmit a registration as well. Moving to the next slide, this shows that you re registering for the program this slide here says you re resubmitting your information just to show you a difference and how that would look if you selected that. It shows that this individual has already completed all of the different areas of registration which includes general information, personal information, business address and phone and then you would click again submission there at the bottom. It s important to use the buttons at the bottom in order to navigate through the site as well and not use the back button; we think it s pretty typical for folks when they re registering for things like this. The next slide shows you what it would like as you re selecting between Medicare and Medicaid for eligible professionals. So if you select the Medicaid button, you would get different information than if you select the Medicare button. This slide shows you if someone has selected Medicare but the field that we want to point to at the bottom here is, Do you have a certified EHR? And the answer would be yes or no. If you select no, it does not stop you from registering, you can register without having a certified EHR; however, at the point of attesting for the program either in Medicare or for Medicaid you do need to have that information. So, at some point before you get a payment you do need to have that. You don t have to have it at registration so if you re interested in this program today as a result of this call and you decide to go and register but you don t yet have certified EHR technology that s fine, you can still go this far and say no I don t have that and it s not a problem. That field there at the bottom doesn t open up if you say no. Moving to the next slide. This is what it looks like if you select Medicaid; you d hit apply and you d see that the Medicaid State or territory field opens up. Currently for eligible professionals, the 11 States that have launched their Page 10

11 programs to CMS so that means they ve met all of our program requirements and they re ready to accept your information and make a payment to you, those 11 States will be in that list for right now. You can click the link next to that; this says Why isn t my State here? if you want to look at a list of known launch dates for your State. So for example, I ll use Maryland because that s where we are right now. Maryland hasn t launched their program yet. So if I m provider in Maryland and I don t see Maryland listed there in the Medicaid State territory drop down box I would click on Why is my State not here? and then that would take me to a page that shows me when Maryland intends to launch their program. We have the best information that we have at any given time we update that State monthly. Some States are very specific that they re going to launch on June 1, 2011; other States give timelines like fall of 2011, or there were a couple that had no known information. Next, you would select your eligible professional type so that would be the five that we talked about earlier and then you would answer Do you have a certified EHR? Yes or no. If you select yes you will be asked for what the certification number is. We re going to talk a little bit more about that at the end of the presentation. The next slide shows you what the registration process looks like for Medicare. It s important to note that this information is derived from current Medicare payment information and the reason we wanted to show this to you is because we don t have that information for Medicaid eligible professionals when they register for this program. What instead is listed are text fields so you would enter where you want your provider where you want your incentive payment to be sent and then the State would validate that. On the Medicare side we do that here. We will validate that against our current files but anything you enter here will be sent to the State. The State is then responsible for making sure that your Tax ID number and your National Provider Identification number selected for payment match each other in a way that makes sense for their system. Page 11

12 So if you came in and you worked at a group practice and you gave us, you know, your cousin s sandwich shop down the street, for your incentive payments to be sent to. The State would say wait a minute, we don t have that relationship on record, let s look at that a little bit more closely so they would reject that. However, if you work at a group practice and your practice receives Medicaid payments all the time, you use the correct NPI and Tax ID number combination no problem the State should send you an incentive payment at that Tax ID number. Moving to the next slide, this is the legalese I talked about at the beginning so you as an individual who registered for this program using the NPPES web user account information provided all this information so far and you re saying that you agree and that you are legally on the hook for that information. So it s important to keep that in mind. Again, we want to point out, we re not encouraging folks to share their user ID and password with anyone else to register on their behalf. CMS is looking at adding functionality hopefully this spring that will allow someone to do that on your behalf but we have not added that yet so until that is in place please don t share user names and passwords. So at the point you click submit and agree to the legalese you move onto the next. At that point going out behind the scene we re processing your information to make sure that we think you re eligible. So for example, we ve checked the Death Master File, we ve checked the OIG exclusions list, Medicare has checked a number of other things in the Medicare file and this person had a failed submission that means that they were probably on the Death Master File or the OIG exclusions list or something else and we re getting some extra information about what steps to take there. We re going to show you in a couple of slides what a successful submission looks like as well, so don t worry. And then you ll see at the bottom you have a Registration ID for tracking purposes. So if there are questions we do have a helpdesk and you can talk to them too and you would need that Registration ID to help expedite that process. Presentation Slides 25 through 45 Page 12

13 Moving to the next slide, we start looking at some eligible hospital slides that would be different from the eligible professional slides. So for one, hospitals have to enter their CMS Certification Number. Eligible professionals don t have a CCN. This is again, the same thing as a provider number, your OSCAR number, so that is entered here and that would help us identify which hospital is actually signing up for the program according to our system. Moving to the next slide, as we mentioned earlier, hospitals can register for either Medicare, Medicaid, or both Medicare and Medicaid in the cases that they re eligible for both programs. So in the case here, if they we ll see on the next slide what happens if they select both Medicare and Medicaid. But again, you can see that they have to also say Do you have certified EHR technology? yes or no, and then provide that information if they have it. Moving to an I m sorry, it s also important to mention on this slide that if you are a hospital that is eligible for both Medicare and Medicaid. And so if you look at the program requirements and you say yes we fall into that bucket for both; we have the 10 percent Medicaid patient volume where either a subsection(d) or a Critical Access Hospital, no problem we meet the requirements for both. You should register for both. Just because you think oh, we re just going to get the Medicaid incentive early in 2011, and then maybe come back later and apply for the Medicare incentive later in the year and we ll just apply for Medicare then, you re still eligible for both Medicare and Medicaid and that s the field you need to select. Moving to the next slide, this shows you what happens when you select both Medicare and Medicaid. Similar to eligible professionals you have to then select a State. Unlike eligible professionals, that drop down menu contains all of the States and territories that might launch a program. We do expect all States and territories eventually to launch a program, but this list will have all of them, even if they re not in that group that s already launched their program. So again, I ll use Maryland as an example, let s say I m Johns Hopkins Hospital I come in and I say I m eligible for both Medicare and Medicaid then I select Maryland from that drop down menu? What happens next is that I Page 13

14 will still be processed for my Medicare payment this spring when I can come back and attest and so on for the Medicare program. But my Medicaid file, for the hospital will be on hold until the State launches their program. So say Maryland comes along in October and they launch their program. As soon as we flip the switch for them to launch their program, they ll receive Johns Hopkins files and they need to make a payment to them as well. So for hospitals, if you select both you also have to select the type. So again, that might be, you know, Acute Care Hospital and subsection(d) hospital for the two programs. And then again you see at the bottom the certified EHR, this person said no so that field is not open. So this is what a successful submission screen looks like. You ll note that it says you ve successfully registered for the EHR Incentive Program. It gives you some other information. The important step here for Medicaid providers is that you are not done with the process. You do have to go to your State s site and finish your eligibility verification. You ll notice in these slides we didn t see anything about patient volume or practicing predominantly so the State asks you all of those questions. The reason is that those questions can vary in terms of the data sources the States are using or any other modifications they ve made to their program in order to increase eligibility. So States will take a look at that. Our files are sent nightly, so we say after 24 hours please continue the process. If you try to go straight from the successful registration screen to your State s site, they won t have your information yet. You do need to wait a day and then go back. States will also be reaching out to you to make sure that there s some continuity between that process. Again at the bottom here, you see the Registration ID number, it s important to keep that tracked. The most important thing about this screen, besides if you re Medicaid provider you re not done, is that we are not sending you an confirmation telling you, hey, we received your registration, you registered for this program. Page 14

15 Like if you go on Amazon or Zappos and buy some shoes, you immediately get a confirmation that they received your submission and that your shoes are on the way. In order to get this program up and running in January, there were some things that we weren t able to enable and that was one of them. So while in the long term of the program, we do expect to be able to send confirmations in the future. We re not doing that right now, so you do need to take an electronic screen shot of this or you need to print out this page so that you have it for your record. Moving to the next slide, so as we mentioned, if you re a Medicaid provider you need to go to your State process in order to finish the program requirements. So we have a couple of slides here from the State of Michigan s EHR Incentive Program to show you generally what it looks like when you go to the State. It s generally a similar look and feel to what we were looking at here for the CMS site. Here you can see Michigan has received their file from a for Ellen Johnson and has pre-populated all of the information they have on that provider so Michigan has information based on the National Provider Identifier as well. They ve brought in some additional information as well as everything that was sent in the file from your registration with the Federal site. You could see over here on the right, they have tabs for how to get through their process and the things you need to answer as well as some general tabs at the top, too. Moving to the next slide you ll see where they re asking about some different program nuances so Are you a pediatrician? They re asking that because they ll have different patient volume requirements for being a pediatrician. Are you a Physician assistant? Physician assistants are only eligible on certain circumstances so they re trying to figure out do we need to ask more questions of this provider. Then at the bottom here, you could see where they ask questions about the patient volume requirements and so on. Moving to the next slide just like the CMS site, there s an attestation site where you will have some legalese where you were saying, yes, I agree to everything that I have submitted here, it s true and accurate and your penalty Page 15

16 is tar and feathering and all kinds of other things that the feds might do to you if you provide wrong information. So then and you re considered registered. Your registration is complete with the State, too. What happened here is the State then begins processing your eligibility information using the data sources they have available to them. So for example claims data, encounter data, et cetera, to make sure that you met all the program requirements. Some States had really great systems for doing this. They were able to automate this process very quickly. Kentucky, great example from the beginning; they re automating a lot of this so they can make provider determination over a 24-hour period and turn out a payment very quickly as well. Other States had older systems and they weren t starting from the same starting line on this, so it might be a little bit slower to verifying some of these requirements for providers. So depending on your State, you may receive a payment very, very quickly or it might be up to five months. The next slide we talk about the Certified Health IT Products List or what we call the CHPL (or chapel ). This site is run by the Office of the National Coordinator who is in charge of making sure that the products out there are certified to meet Meaningful Use. You do need to go to this site in order to get a number from the CHPL in order to plug that back number back in the CMS registration site. So let me give you an example. Let s say I have an Epic Electronic Health Record system and I have a couple of different modules like for e-prescribing in order to meet the Meaningful Use requirement. All of this is products that need to be entered here at the CHPL site and then you ll get a unique number at the end that says that this collection of technology will meet Meaningful Use and then you ll use that number on the CMS site. I just want to emphasize that this was not your vendor may have a certification number as well and that s different; that s not the same thing. Page 16

17 We ve got one of our CMS experts on the line to answer questions about that as well who s worked quite a bit on the issues related to the CHPL. So Larry Clark will be able to answer some questions later on that. Finally, the last slide, this goes over some resources for you. We tried to make our website as helpful as possible. We have Frequently Asked Questions, we have an Eligibility Wizard that ll allow you to plug in some very basic information to see if you might be qualified for this program. We have our EHR Information Center phone number on here. Regional Extension Centers that are run through grants from the Office of the National Coordinator are also looking forward to helping providers get to Meaningful Use. They only work with certain provider practices that are the primary care oriented and so on. So that wouldn t necessarily apply to all of the Medicaid EPs or hospitals. And finally, our Final Rule is out there for anyone who wants some great bedtime reading. We have a very long final rule that goes through all of these requirements and you too can be an expert on this program. So with that, I ll turn it back over to Diane for questions and answers. Diane Maupai: Thanks, Michelle, for a great presentation. Sarah, could you please open the line for questions. Question and Answer Session We will now open the lines for a question and answer session. To ask a question please press star followed by the number one on your touchtone phone. To remove yourself from the queue please press the pound key. Please state your name and or organization prior to asking a question and pick up your handset before asking your question to assure clarity. Please note your line will remain open during the time you are asking your question so anything you say or any background noise will be heard in the conference. Your first question comes from the line of Tim Walters. Your line is open. Page 17

18 Tim Walters: Thank you, this is Tim Walters I work in Citizens Memorial Hospital in Bolivar, Missouri. I ve got two different questions concerning the Medicaid eligible professional criteria, the 30 percent criteria. We have both Rural Health Clinic physicians as well as other physicians that are not practicing in RHCs. First for the ones who are not in our RHCs, I know that when measuring the Medicaid volume we have to exclude patients under the CHIP Program from the numerator, we re not aware of a way to do that with the information we have and I don t know is that how do we determine which patients have CHIP and which patients are under, I guess, traditional Medicaid. Sure, thanks Tim that s a really great question. So I want to clarify a couple of things first. One is that any of your physicians or other eligible professionals that are considered hospital-based so in other words more than 90 percent of their professional services were provided in an inpatient or emergency department setting will not be eligible for this program. Secondly, the folks that work in the Rural Health Clinic they don t have to meet the Medicaid patient volume requirements they can meet the needy individual patient volume requirements in order to qualify, which is much easier because the payer sources can be Medicaid, CHIP or folks that are receiving sliding scale or free services based on income. Finally, so these other professionals that do need to meet the Medicaid patient volume requirement, you re asking how do you figure out if a client has Medicaid or CHIP as their payer source in order to count them in your numerator for patient volume. This is a complex question, so in our Final Rule we said that when the program is authorized under a section 1115 Demonstration Waiver then under Title XIX, I m sorry, Title XIX is Medicaid. When a CHIP Waiver or an 1115 Waiver is authorized like that under Title XIX they can be included in the patient volume numerator. However, most Medicaid programs are not authorized that way. We re looking in the future about ways you can be more flexible with that process but right now what a lot of states are doing is they re saying, you know, you re in Jefferson County Missouri and Jefferson County has 20 percent of their kids are Medicaid and 10 percent of their kids are CHIP so you need to Page 18

19 apply those values to any kid you have in Missouri HealthNet Program in order to get an eligibility determination. So they re applying the county or State level proxy values to the individual providers because the payment source will often be unknown by the provider especially in these programs that has CMS eligibility or a continuous eligibility programs. We know that in most case I ve tried to make that process as easy as possible for both the beneficiaries and the providers so that will usually be the case. Your State s State Medicaid Health IT plan, which is something they require to submit to us for review and approval should address this issue so I recommend contacting your State Medicaid agency Missouri has a website, I would check out their website and see if they define this a little bit better in terms of how you should get to that determination. Tim Walker: Tim Walker: All right, we ll check with the State on that one. The other one is more specific to our records for our Rural Health Clinics and we have several of them, 10 of them to be specific. We have obviously a lot of data that we keep on the patients and we are going through, we ve been able to track down the Medicaid data including CHIP and that s not been a problem. For the uncompensated care patient population within our system we ve been able to identify those in the aggregate for all of our Rural Health Clinics we haven t been able to split that down to the clinic level in other words we know for all 10 rural health clinics just about three percent of our patient volume is for uncompensated care service with individuals who meet sliding scale discount policies or, you know, indigent care et cetera. What we re trying to do is determine can we use that overall factor for the Rural Health Clinics across all the clinics to measure for our providers as opposed to manually going through the records to try and determine which patient might apply to which clinic. You would need to work with your State on that to see how they would like to operationalize that in your circumstances. OK, so just work with State on how they will implement that, OK. It s been our experience that the State staff that work on the EHR Incentive Program are just outstanding and they re bending over backwards they want Page 19

20 this money in providers pockets and they will work with you as much and often and as fast as possible in order to get your questions answered and they often send them back to us as needed, too. Tim Walker: Todd Foyet: Larry Clark: Todd Foyet: Larry Clark: Todd Foyet: OK thank you. You re welcome. Your next question comes from the line of Todd Foyet, your line is open. Yes, I was concerned with the issue of certification of the EHR. If the EHR meets certification for 2011 and 2012 but is not updated to meet certification for 2013, what would be the process or what would be the events that would occur for someone who has applied? So Larry Clark is our CMS point person, our subject matter expert on the certification requirements. Larry, can you answer his question about what happens when a provider receives certification for the first two years of the program and then what happens in Well, right now we re working through the issues of what Stage Two would look like so that may or may not change but if there is a need to re-certify a system that will be announced later. OK thanks Larry. Todd, does that answer your question? Just to clarify you may not need to recertify then as long as for example, we re using Epic, which is currently certified so if they don t meet the certification requirements or if there is no need to re-certify in 2013, we ll discontinue on with the process. If you go to the CHPL and you put that product in you will receive a CMS EHR Certification ID Number that will tell you if that product is in fact certified for this program. Thanks, Larry and Todd. Thanks, Todd. Thank you. Page 20

21 Your next question comes from the line of Donna Garwood, your line is open. Donna Garwood: Thank you, can you hear me. Yes. Donna Garwood: OK, I m asking this question on behalf of one of the hospitals in Kansas and so I m just going to read what s written for me. Oh, and I am Donna Garwood and I m the HIT Regional Extension Center Educator for the State of Kansas. This hospital is aware that they will be purchasing a certified electronic record system that will be capable of producing al the Meaningful Use measures for them for reporting. The question is, specifically we have a certified gender and all of the software required to meet all of the objectives that we plan to use to qualify for Meaningful Use. We have not, however, purchased the software that is available from the vendor that that we are not planning to use to meet the stage one requirements, must we purchase modules that will not be used for another one and half years. Donna, I m going to ask you to follow up with ONC because this we really need to get to the questions for this presentation that relate to registration on the Medicaid requirement. Donna Garwood: I m sorry. So if you could follow up with ONC that would be great. Donna Garwood: All right. Thanks. Linda Seville: Your next question comes from the line of Linda Seville. Your line is now open. This is Linda Seville from Stormont-Vail Healthcare in Kansas. The question about the payment; OK, right now when we re not eligible or can even register in Kansas for the Medicaid but if were to choose just for the professional side for the Medicare and let s say we don t register until maybe June, are we going to get payment from January 1st through the whole year or does it start after you register? Page 21

22 Linda Seville: Linda Seville: So Linda thanks for your question. You re correct, the Medicaid program in Kansas hasn t launched yet. I don t want to get too far into the Medicare requirements today, we re just covering the Medicaid topics, we didn t bring any of our Medicare subject matter experts and I might say something that s wrong and I don t want to put incorrect information out especially since we re having a transcript and a recording so we do plan our follow-up calls about Medicare registration. We have lots of information on our website as well and we hope that you ll attend when we have that Medicare call. OK. Well, for the Medicaid I m assuming that because it s not even available it s going to go back for the whole year for payment. So if Kansas launches - it s not based on a period per se so the difference between Medicare and Medicaid here is that for Medicaid you receive a flat incentive payment in your first year so you receive 21,250 unless you re a pediatrician participating at a lower patient volume and then you get two thirds of that amount. So generally the 21,250 is a discrete number for Medicaid. For Medicare, the incentive is based on your Part B allowed charges up to a certain amount so, when you re asking about what point in time would you get paid during the year, it depends on an accrual of your Medicare charges but I definitely don t want to get into that today. For Medicaid if Kansas launches their program in, you know, June in this year you would get the same amount as if they had launched in January and I think maybe that s what you re trying to get at; it won t impact providers. OK, so Medicaid it won t impact and I need to wait to find out about Medicare, thank you. You bet. Your next question comes from the line of Ezequiel Sandoval, your line is now open. Ezequiel Sandoval: Hello. This is Ezequiel Sandoval with Infinite Consulting Services in Northern California. I have two questions; one for Critical Access Hospitals you mentioned that one of the requirements is the length of stay less than 25 Page 22

23 days. If you could just clarify quickly, is it 25 or 21 days and are long-term care beds or distinct part bed that s included in that calculation. Two things on this, one is that I just want to clarify that you re asking about the Medicaid eligible hospital requirement for acute care hospitals that they have an average length of stay as 25 days or fewer. Critical Access Hospitals we believe also under that bucket because they have certification requirements that require that they have length of stay of 96 hours or fewer so they are processed pretty quickly in Critical Access Hospitals and we don t expect them to have a problem meeting that. In terms of the additional bed days it depends on how they complete their cost report. We do have an FAQ on our website that gets into more detail about that. Ezequiel Sandoval: Yes, excellent, thank you that does answer that question. The other question has to do with the hospital-based providers 90 percent calculation, is that calculated based on the number of encounters or the number of charges, 90 percent of the charges that that provider performs in the hospital. That s a very timely question. We re in the process now of getting an FAQ put on our website that addresses that. I want to point out that with respect to Medicare and Medicaid there are different requirements for how a hospitalbased eligible professional determination is made, for Medicare eligible professionals it s based on their Medicare claims, for Medicaid it would be based on their Medicaid claims as well but not just the claims that they re in and a State has a lot of managed care so since 70 percent of our Medicaid program nationally is managed care we also need to take a look at encounter data so most States will have that determination made on the basis of combining the encounters and claims data for Medicaid in order to determine that. I just want to check in with Larry Clark who s on the line and see if he has anything to add to that. Larry Clarke: No, that sounded pretty good. We are currently working through the frequently asked questions that area. Page 23

24 Diane Maupai: OK. So we encourage folks to check back. Hopefully, we were hoping that it would be posted by today before the HIMSS Conference next week but we have to get, legal questions like this clear to a number of folks so it looks like it ll be next week when it s posted so just check back. Hi, this is Diane; I m going to ask everyone a favor. We have a lot of people waiting to ask questions so if you could limit yourself to your one most important question. At the end of the presentation today I ll give you a number you can call and direct any other questions you might have.thank you very much. Your next question comes from the line of Ferdinand Velasco, your line is open. Ferdinand Velasco: Thanks, good afternoon. Ferdinand Velasco from Texas Health Resources, a question about the step after registration for eligible hospital, currently the person who controls the NPPES web login is a senior vice president of finance so he s the one that s done the registration but for the next step which is the attestation for Meaningful Use, would it be he the person or is there some way that he can designate somebody else to perform the attestation for Meaningful Use? Paige Falk: Yes, that s a really great question and Paige and Nancy are on the line, she should definitely correct me if I m wrong about this but the processes to go in and request the change in your Authorizing Official or your AO as its documented in some places in order to have someone else make that change your current Authorizing Official, which sounds like is going to be your senior VP is we need to authorize the addition of a new AO. Paige or Nancy, do you want to add anything to that? Yes, this is Paige; the only thing that I would say is that actually you don t have to request a new Authorized Official you can have the person working on behalf of the hospital request access as an end user. In that way the Authorized Official should remain and that first that Authorized Official would provide approval for the end user to come in and attest on behalf of the hospital. Page 24

25 Ferdinand Velasco: Excellent, thank you very much and it would be helpful to share that via frequently asked question on the website, thanks. Thank you very much for making that suggestion. We are in the process of getting more detailed information put together about some of these registration nuances like I mentioned in the slides, the number of different systems where we re pulling information and in order to expedite this whole registration and attestation process so as a result there are a couple of little perks for some providers and we are looking at getting more information out about that so thank you. Your next question comes from the line of Raymond Kreichelt. Raymond Kreichelt: This is Ray Kreichelt I m with Nemours in Jacksonville, Florida, we re a pediatric organization. My question is to do with whether or not we can receive incentive payments this he first year based on adoption, implementation and upgrade or whether we must show a Meaningful Use. We had certified Electronic Health Records in place before 2011 so in essence we re not going to be putting them in place in 2011 but it would be a lot easier for us this first year to apply under the AIU as opposed to the Meaningful Use. Great. So thank you, that s a really great question and it allows me to touch on two things. One is that in order to participate in this program for Medicaid you don t have to Meaningfully Use in your first year; you can adopt, implement or upgrade certified EHR technology. The second issue is that the certification program started in the fall of 2010 so if you had something that had like an older CCHIT certification or some other vendor certification prior to that time that is not considered certified in order to meet Meaningful Use for this program. Everyone does have to go to the CHPL or the Certified Health IT Products List in order to get a certification number to make sure that the product is certified in order to meet Meaningful Use. The reason we re doing that to show some background is that there are a lot of products out there that were certified prior to these new standards and requirements that they don t talk to each other. They don t meaningfully exchange health information or do a number of the other activities required to Meaningful Use in this program so we have new and different certification program and folks Page 25