Agency Header

Frequently Asked Questions

WV MEDICAID EHR PROVIDER INCENTIVE PAYMENT PROGRAM

GENERAL QUESTIONS: (Click on each question for details)

  1. What is this federal incentive program for the implementation of electronic health records?
  2. Why has this EHR incentive program been established?
  3. How much in incentive payments are available for West Virginia?
  4. Which providers are eligible for the CMS health information technology meaningful use incentive payments?
  5. Which providers are eligible for the Medicaid incentive payments?
  6. How will Medicaid incentive payments be made?
  7. What are the eligibility parameters for Medicaid Eligible Hospitals?
  8. What is “meaningful use?”
  9. What types of activities are included in the detailed requirements for meaningful use?
  10. What will be needed to meet the new meaningful use requirements?
  11. Who decides whether a provider meets the meaningful use criteria and can receive an incentive payment?
  12. What is the required registration and attestation process?
  13. What are the promoters in order to qualify for first-year payment under AIU?
  14. Will the Medicare/Medicaid incentives be provided to providers or to the health care entity? Are there resources available to assist health care providers with EHR adoption and meaningful use?
  15. What are the Medicaid incentive eligibility thresholds in the first year and how are they determined?
  16. My application for the PIP Program was denied?  How can I appeal this decision?
  17. I'm registered with the Provider Enrollment, Chain and Ownership System (PECOS) and the National Level Repository (NLR) using a National Provider Identifier (NPI) that is not in the West Virginia Medicaid Management Information System (MMIS) or affiliated with a number in the West Virginia MMIS.  What do I need to do to register?
  18. When is the last day an EP or eligible hospital has to attest for 2011?

December 31st, 2011 was the last day for eligible hospitals to register and attest to receive a Medicaid incentive payment for federal fiscal year (FY) 2011.
There are two factors that determine the Electronic Health Record (EHR) reporting period for eligible hospitals for both the Medicare and Medicaid EHR Incentive Programs:

  • Whether the hospital is attesting to Medicaid only; Medicaid first, then Medicare in the same fiscal year; Medicaid first, then Medicare in a later fiscal year; or Medicare and Medicaid simultaneously/Medicare first, then Medicaid in a later fiscal year.
    The payment year for which the hospital is attesting (first, second, third etc.)
  • See the table below (where having adopted, implemented, or upgraded to certified EHR technology for Medicaid is abbreviated as AIU and meaningful use is abbreviated as MU):  

Hospital Participating In:

Payment Year

Medicaid Incentive Program Only

Medicaid 1st, then Medicare in same FY

Medicaid 1st, then Medicare in later FY

Medicare and Medicaid Simultaneously / Medicare 1st, then Medicaid in a later FY

1st payment year

AIU

AIU (Medicaid);

AIU

MU, 90 day reporting period

MU, 90 day reporting period (Medicare)

2nd payment year

MU, 90 day reporting period

MU, 12 month reporting period

MU, 90 day reporting period

MU, 12 month reporting period

3rd payment year

MU, 12 month reporting period

MU, 12 month reporting period

MU, 12 month reporting period

MU, 12 month reporting period


Relevant points to remember regarding eligible hospitals:

  • Hospitals that are eligible for EHR incentive payments under both Medicare and Medicaid should select "Both Medicare and Medicaid" during the registration process, even if they initially plan to apply for an incentive under only one program.
  • A hospital that is a meaningful EHR user under the Medicare EHR Incentive Program is deemed to be a meaningful user for Medicaid. CMS will audit hospitals eligible for both the Medicare and Medicaid EHR Incentive Programs for compliance with the meaningful use requirements under the Medicare program. The states are responsible for auditing AIU and other requirements for receiving an EHR incentive payment, such as patient volume.
  • There will never be two consecutive years of 90-day reporting periods for meaningful use. The 90-day reporting period is always followed by a 12-month reporting period the following year, irrespective of when attestation occurred and whether to Medicare or Medicaid.
    The reporting period must begin and end in the Federal Fiscal Year that constitutes the payment year.
  • There is no reporting period for adopt/implement/upgrade.
    A hospital participating in the Medicaid EHR incentive program must meet all Medicaid requirements, including patient volume requirements.  
March 31st, 2012 is the last day for eligible professionals to register and attest to receive a Medicaid incentive payment for calendar year (CY) 2011.
  • In the first payment year, an eligible professional must attest to AIU to certified EHR technology. In the second payment year, the eligible professional must demonstrate meaningful use (MU) of certified EHR technology for a continuous 90 day period within that program year. For the third and subsequent years, the eligible professional must demonstrate MU for the entire calendar year (365 days). For each program year, the eligible professional must meet patient volume requirements for a continuous 90 day period in the preceding calendar year.

HOSPITAL QUESTIONS:

  1. Will a hospital use the cost report S-10 worksheet for charitable contributions?
  2. How is Medicaid Share defined?
FQHC QUESTIONS:
  1. If I am with an FQHC, what qualifies for the 30% patient requirement under the Medicaid tract?
  2. What will be required by Medicaid for the registration and attestation requirements to assign payment to FQHCs….particularly for part-time providers associated with an FQHC…who may have their own private practice? What specific guidance will be provided?  
Need to ask about something not answered here?
Please submit questions by email to dhhrehr@wv.gov or call 1-888 483 0793 and select option 8 when prompted.


  1. What is this federal incentive program for the implementation of electronic health records?  
    As part of the American Recovery and Reinvestment Act, the Centers for Medicare & Medicaid Services (CMS) is authorized to provide a reimbursement incentive for eligible Medicare and Medicaid providers (physician and hospital providers) who are successful in implementing electronic health records and achieving “meaningful use,” as defined by the U.S. DHHS. These incentive payments began in 2011 and gradually will phase down. NOTE: Starting in 2015, providers are expected to have adopted and be actively utilizing an EHR in compliance with the “meaningful use” definition or they will be subject to financial penalties under Medicare. Stimulus funding for participating practices who implement EHRs will range from a maximum of $44,000 per eligible provider over five years under Medicare or $63,750 per provider maximum under Medicaid. Again, these funds will be available to eligible providers who acquire a certified EHR and demonstrate they are using the technology to improve the health of patients through meaningful use of the EHR and its data. Information on the Medicare and Medicaid EHR Incentive Programs, including a link to the text of the final rule, can be found at http://www.cms.gov/EHRIncentivePrograms(Top of Page)

  2. Why has this EHR incentive program been established? 
    The purpose of this program is to encourage the adoption of electronic health records across the nation, particularly among small primary care practices and physicians.  (Top of Page)

  3. How much in incentive payments are available for West Virginia?
    Eligible Hospitals and eligible health care providers who adopt certified electronic health record systems under his program could receive, in total, hundreds of millions of federal dollars under this program.  (Top of Page)

  4. Which providers are eligible for the CMS health information technology meaningful use incentive payments? 
    The Centers for Medicare & Medicaid Services (CMS) announced July 13, 2010 a rule to implement the provisions of the American Recovery and Reinvestment Act of 2009 (Recovery Act) that provide incentive payments to providers for the meaningful use of certified EHR technology. The Medicare EHR incentive program will provide incentive payments to Eligible Professionals (EPs), Eligible Hospitals, and critical access hospitals (CAHs) that are meaningful users of certified EHRs. An EP may receive incentives from either Medicare or Medicaid, but not both. Each provider must elect their program participation selection during the registration process with CMS. Eligible Professionals will be permitted to change that selection once during the life of the incentive program. Dually eligible Hospitals, including Critical Access Hospitals may receive incentive payments from both Medicare and Medicaid. Click here for more info. Hospitals that are eligible for EHR incentive payments under both Medicare and Medicaid should select “Both Medicare and Medicaid” during the registration process. Hospitals who register only for the Medicaid program (or Medicare) will not be able to change their registration after payment is initiated.  (Top of Page)

  5. Which providers are eligible for the Medicaid incentive payments? 
    Eligible Professionals (EPs) are physicians (primarily doctors of medicine and doctors of osteopathy), dentists, nurse practitioners, certified nurse midwives, and physician assistants practicing in a Federally Qualified Health Center (FQHC) or Rural Health Clinic (RHC) that are so led by a physician assistant. EPs must attest that 30% of their patient encounter volumes are Medicaid. Pediatricians can qualify for incentive payments with Medicaid patient volume between 20% - 30%; however, their incentive payment is reduced to 2/3rds of the total incentive amount available. EPs practicing predominately in a FQHC or RHC are allowed to include encounters for “needy individuals” toward meeting their Medicaid patient volume. An EP is considered to practice predominately at an FQHC or RHC when more than 50% of the EP’s total patient encounters over a period of six (6) months occur at the FQHC or RHC. . “Needy individuals” include those patients whose services are paid for by Medicaid or Children’s Health Insurance Program (CHIP), provided at no cost or at a reduced cost based on a sliding scale determined by the individual’s ability to pay.
    NOTE: As with Medicare, hospital-based EPs who provide “substantially all of their professional services in a hospital setting” are not eligible for Medicaid incentives.        (Top of Page)

  6. How will Medicaid incentive payments be made? 
    For Eligible Professionals:
    Medicaid EPs who adopt, implement, upgrade, or meaningfully use certified EHR technology in their first year of participation in the program, will be eligible for an incentive payment of $21,250. In subsequent years of payment, a Medicaid EP’s incentive payment will be limited to $8,500. EPs may start participation in the incentive program as late as 2016 and still be eligible to receive the maximum payment; the six participation years need not be consecutive. Pediatricians who meet the 30 percent patient volume requirement may qualify to receive the maximum incentive payments. Incentive payments for pediatricians who meet the 20 percent Medicaid patient volume but fall short of the 30 percent Medicaid patient volume are reduced to two-thirds of the incentive payment. See tables below for Eligible Professional (Pediatrician) incentive payments over calendar years.        

    For Eligible Hospitals:
    The overall Medicaid EHR incentive amount is calculated for each hospital at the time of initial application for the incentive payment. However, the regulations allow States to pay the incentive amount over a period of three to six years. In West Virginia, BMS will make payments to hospitals over a three-year period, paying 50% of the total amount in the first year of participation, 40% in the second year, and 10% in the third year. Once a hospital applies for and receives the first payment, the hospital has 6 years to meet the meaningful use objectives, apply for and collect the remaining two payments. This means that payment years need not be consecutive. The total incentive amount for each hospital is unique and is formula-driven. It is the sum over a theoretical four years of payment where the amount for each year is the product of three factors:
         1. An Initial EHR Amount,
         2. A Transition Factor applicable to each of a theoretical four years,
         3. The Medicaid Share.   (Top of Page)

  7. What are the eligibility parameters for Medicaid Eligible Hospitals?
    MEDICAID ELIGIBLE HOSPITALS -- Specifies that an acute care hospital is a primary health care facility where the average length of patient stay is 25 days or fewer. Hospitals with an average length of stay of 25 days or fewer and with a CMS Certification Number (CCN) that has the last four digits in the series 0001 – 0879 or 1300-1399 are eligible. This specification will include short term general hospitals, the 11 cancer hospitals, and critical access hospitals in the United States, District of Columbia, and U.S. territories. Acute care hospitals also must have 10 percent Medicaid patient volume in order to participate.
    For children’s hospitals, the regulation specifies that only those hospitals that have CCNs in the 3300-3399 series will be considered children’s hospitals.   (Top of Page)

  8. What is "meaningful use?"
    This is the term being used by the Office of the National Coordinator (ONC) and the Centers for Medicare and Medicaid (CMS) to describe the federal criteria eligible providers must meet to qualify to receive financial incentives for using electronic health records (EHRs) in a meaningful manner.
    Health care entities with EHRs do not realize full benefits merely by transferring information from paper form into digital form. EHRs can only deliver their benefits when the information and the EHR are standardized and “structured” in uniform ways, just as ATMs depend on uniformly structured data. Therefore, the “meaningful use” approach requires identification of standards for EHR systems. Similarly, EHRs cannot achieve their full potential if providers don’t use the functions that deliver the most benefit – for example, exchanging information, and entering orders through the computer so that the “decision support” functions and other automated processes are activated. Therefore, the “meaningful use” approach requires that providers meet specified objectives in the use of EHRs, in order to qualify for the incentive payments.   (Top of Page)

  9. What types of activities are included in the detailed requirements for meaningful use?
    The meaningful use criteria will involve three stages that are being rolled out over time. Only the Stage 1 criteria have been finalized at this point.
    Stage 1 Criteria for Meaningful Use:  The Stage 1 criteria for meaningful use focus on electronically capturing health information in a coded format, using that information to track key clinical conditions, communicating that information for care coordination purposes, and initiating the reporting of clinical quality measures and public health information.
    The criteria for meaningful use are based on a series of specific objectives, each of which is tied to a measure that allows EPs and hospitals to demonstrate that they are meaningful users of certified EHR technology.
    For Stage 1, which begins in 2011, there will be 25 objectives/measures for EPs and 24 objectives/measures for Eligible Hospitals. The objectives/measures have been divided into a core set and menu set. EPs and Eligible Hospitals must meet all objectives/measures in the core set (15 for EPs and 14 for Eligible Hospitals). They can choose to defer up to five remaining objectives/measures.
    In 2011, EPs, Eligible Hospitals and CAHs seeking to demonstrate Meaningful Use are required to submit aggregate clinical quality measure numerator, denominator, and exclusion data to CMS or the States by attestation. In 2012, EPs, Eligible Hospitals and CAHs seeking to demonstrate meaningful use must electronically submit clinical quality measures selected by CMS directly to CMS (or the States) through certified EHR technology. CMS recognizes that for clinical quality reporting to become routine, the administrative burden of reporting must be reduced. By using certified EHR technology to report information on clinical quality measures electronically to a health information network, a State, CMS, or a registry, the burden on providers that are gathering the data and transmitting them will be greatly reduced.
    Beyond the Stage 1 Criteria for Meaningful Use:  The policy goals of meaningful use will be most fully realized by building on findings from Stage 1 and by making full use of the greater proliferation of certified EHR technology and supporting HIT/E infrastructure that will take place under Stage 1. CMS intends to propose, through future rulemaking, two additional stages of the criteria for meaningful use.
    Draft criteria for Stage 2 have been published; they expand upon the Stage 1 criteria in the areas of disease management, clinical decision support, medication management support for patient access to their health information, transitions in care, quality measurement and research, and bi-directional communication with public health agencies. These changes are reflected by a larger number of core objective requirements for Stage 2.
    CMS may also consider applying the criteria more broadly to the outpatient hospital settings (and not just the emergency department). Information exchange is a critical part of care coordination and we expect that the infrastructure will support greater requirements for using health information exchanges for Stage 2. Stage 3 will focus on achieving improvements in quality, safety and efficiency, focusing on decision support for national high priority conditions, patient access to self-management tools, access to comprehensive patient data, and improving population health outcomes.
    Click here for a Meaningful Use Overview.     (Top of Page)

  10. What will be needed to meet the new meaningful use requirements?
    In order to qualify to receive the incentives, health care providers must first meet certain eligibility criteria and demonstrate that they are using certified EHR systems in a meaningful manner. However, in the initial year, Eligible Professionals and Eligible Hospitals may receive the Medicaid incentive payment if they have adopted, implemented or upgraded (AIU) to certified EHR technology. (More on AIU below.)   (Top of Page)

  11. Who decides whether a provider meets the meaningful use criteria and can receive an incentive payment?
    The Medicare incentive program is administered by CMS through its local fiscal intermediaries.. Systems for collecting meaningful use clinical outcomes measures and for applying for incentives have been developed and are now online. The first year is being implemented through an attestation system only. After the first year, the numerator and denominator for each meaningful use objective must be submitted electronically from a certified EHR.
    The Medicaid incentive program is administered by each state’s respective Medicaid agency. The Department of Health and Human Services, Bureau for Medical Services is the designated agency for West Virginia.
    (Please send an email to dhhrehr@wv.gov to receive an email notification when the West Virginia Medicaid registration is ready.)   (Top of Page)

  12. What is the required registration and attestation process?
    The Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) have started the “registration and attestation” program to provide Medicare and Medicaid incentive payments to eligible healthcare professionals and hospitals who qualify.
    Health care professionals who meet the eligibility requirements under the Medicare or Medicaid EHR Incentive Program must select which program they wish to participate in when they register. They cannot participate in both programs; however, after receiving payment, they may change their program selection once before 2015. Hospitals that are eligible for both programs can receive payments from both Medicare and Medicaid.
    To prepare for registration, interested providers should first familiarize themselves with the Incentive Program’s requirements by visiting the CMS official Web site for the Medicare and Medicaid EHR Incentive Program. Click here to view the CMS EHR Incentive website. The site provides general and detailed information on the programs, including tabs on registration users guides, the path to payment, eligibility, meaningful use, certified EHR technology, and frequently asked questions.
    To begin the registration process for either the Medicare or Medicaid EHR Incentive Programs click here. Providers will need to go to the West Virginia Medicaid EHR Provider Incentive Payment (PIP) web portal to complete the registration and attestation for the West Virginia Medicaid EHR PIP program. Access to the WV EHR PIP web portal (www.wvmmis.com) will be available on August 11th. Providers should wait two (2) days after completion of their NLR registration to begin their WV attestation.
    Need a checklist to help with the process? Click here to access the WV Medicaid EHR PIP checklist.     (Top of Page)

  13. What are the parameters in order to qualify for first-year payment under AIU?
    For AIU (adopt, implement or upgrade), a provider does not have to have installed certified EHR technology. The definition of AIU in 42 CFR 495.302 allows the provider to demonstrate AIU through any of the following: (a) acquiring, purchasing or securing access to certified EHR technology; (b) installing or commencing utilization of certified EHR technology capable of meeting meaningful use requirements; or (c) expanding the available functionality of certified EHR technology capable of meeting meaningful use requirements at the practice site, including staffing, maintenance, and training, or upgrade from existing EHR technology to certified EHR technology per the ONC EHR certification criteria. For the West Virginia Medicaid EHR Provider Incentive Payment program, a provider must demonstrate AIU for year 1 by selecting within the West Virginia EHR Provider Incentive Program web portal whether they have adopted, implemented, or upgraded EHR. However, providers will be responsible for maintaining documentation that supports their attestation of AIU. Additional information is found in the West Virginia Medicaid Provider Manual Common Chapter 800, Section 800.19 Maintenance of Records.    (Top of Page)

  14. Will the Medicare/Medicaid incentives be provided to provider or to the health care entity?  Are there resources available to assist health care providers with EHR adoption and meaningful use?
    The incentives are set up to be paid to the pay to information on record with Medicaid. Please call Molina Provider Services at 888-483-0793 if the pay to information needs to be validated or changed.  Yes. The federal government also has provided funds to assist the health care community with greater use of electronic health records and the fulfillment of the meaningful use standards. One key way is through the establishment of regional extension centers (RECs). In West Virginia, the federal REC is the West Virginia Regional HIT Extension Center (WVRHITEC – www.wvrhitec.org). The center is an independent, non-profit organization providing technical assistance, guidance, and information on best practices to support and accelerate providers’ efforts to become meaningful users of certified electronic health record technology. It is made up of a team of experienced health information technology (HIT) and clinical professionals with intimate knowledge of West Virginia’s medical community. The WVRHITEC has funds available to provide priority primary care providers, generally those associated with FQHCs and small private practices, with subsidized training and services (electronic health record selection and implementation, meaningful use, workflow redesign, privacy & security, etc.).  (Top of Page)

  15. What are the Medicaid incentive eligibility thresholds in the first year and how are they determined?
    For eligible providers, during the first year of incentive program participation, Medicaid volumes are based on encounters over a 90-day period during the preceding calendar year and a full twelve months during subsequent years. The 90-day period is selected by the provider and may be any 90 days during the preceding calendar year. An encounter is defined as an unduplicated direct personal contact (or series of contacts occurring within the same day) between a member and a provider for reimbursable services for which Medicaid (or a Medicaid demonstration project approved under section 1115 of the Social Security Act) paid for all or part of the services. Providers will be asked to submit both their Medicaid/ needy individual (for FQHCs and RHCs) encounter volume as well as their total encounter volume during the incentive application process. Medicaid volumes will be validated against information in the Medicaid claims/payment system.
    For hospitals, Medicaid volume is determined by the number of inpatient discharges and the number of ER encounter over a 90 day period during the first incentive year and a full twelve months during subsequent years. The 90 days used may be any 90 day period during the preceding fiscal year. A Medicaid encounter is defined as an encounter for which Medicaid paid for all or part of the services. Hospitals will be asked to submit the number of Medicaid discharges and ER visits (encounters) as well as their total inpatient discharges and ER encounters during the incentive payment application process. Volume data submitted by the hospital is subject to verification and audit by BMS.   (Top of Page)

  16. My application for the PIP Program was denied? How can I appeal this decision?
    Please contact Provider Relations at 1-888-483-0793, option 6.  The Provider Relations Team can explain the reason(s) for denial and can provide additional information about it.
    Appeals must be submitted within 30 days of the denied application.  Appeals must be submitted directly to the Commissioner for the Bureau for Medical Services at:

    350 Capitol Street
    Room 251
    Charleston, WV  25301

    When submitting an appeal, please follow the directions found in Chapter 800 of the Provider Manual found on the Bureau for Medical Services' website (www.dhhr.wv.gov/bms). Section 800.14 provides information on appeals. (Top of Page)

  17. I'm registered with the Provider Enrollment, Chain and Ownership System (PECOS) and the National Level Repository (NLR) using a National Provider Identifier (NPI) that is not in the West Virginia Medicaid Management Information System (MMIS) or affiliated with a number in the West Virginia MMIS. What do I need to do to register?
    Please contact Provider Relations at 1-888-483-0793, option 6, for assistance in registering.
    (Top of Page)

  18. When is the last day an EP or eligible hospital has to attest for 2011?
    December 31, 2011 is the last day for eligible hospitals to attest for the 2011 fiscal year.  Eligible professionals will have until March 31, 2012 to attest for the 2011 calendar year.  (Top of Page)

HOSPITAL QUESTIONS

  1. Will a hospital use the cost report S-10 worksheet for charitable contributions?
    Information from the hospital’s cost report is the basis for calculating the Medicaid Share below. This includes worksheet S-10 which contains the information on charges attributable to charity care.  (Top of Page) 

  2. How is Medicaid Share defined?
    The Medicaid Share is essentially the percentage of a hospital’s inpatient, non-charity care days that are attributable to Medicaid inpatients. It is calculated using Medicaid inpatient days as a percentage of total inpatient days and is adjusted to account for uncompensated care days.
    The numerator of the Medicaid Share is the sum of:
         • The number of Medicaid inpatient-bed-days and
         • The number of Medicaid managed care inpatient-bed-days.
    The denominator of the Medicaid Share is the product of:
         • The total number of all inpatient-bed-days for the Eligible Hospital during that period and
         • The total amount of the Eligible Hospital’s charges during that period, not including any charges that are attributable to charity care divided by the estimated total amount of the hospital’s charges during that period.
    States must be able to audit the information provided by hospitals through their MMIS, hospital cost reports, hospital financial statements/ audit reports, or other verifiable source. To the extent there is simply not sufficient data that would allow a state to estimate the inpatient bed-days attributable to Medicaid managed care patients, the statute directs that such figure is deemed to equal 0.    (Top of Page)

FQHC QUESTIONS

  1. If I am with an FQHC, what qualifies for the 30% patient requirement under the Medicaid tract?
    For FQHC’s and Rural Health Clinics, the 30% threshold includes “needy individuals” as well as Medicaid beneficiaries.
    During the first year of incentive program participation, the volumes are based on encounters over a 90 day period during the preceding calendar year; the full twelve months of the preceding calendar year are used during subsequent incentive years. An encounter is defined as an unduplicated direct personal contact (or series of contacts occurring within the same day) between a member and a provider and will include encounters for reimbursable services for which Medicaid paid for all or part of the services, as well as encounters for persons with WV-CHIP, uncompensated care, or a sliding fee scale as a payment source.    (Top of Page)

  2. What will be required by Medicaid for the registration and attestation requirements to assign payment to FQHC's....particularly for part-time providers associated with an FQHC...who may have their own private practice?  What specific guidance will be provided?
    A provider is considered an FQHC provider if more than 50% of their encounters over a period of 6 months during the most recently completed calendar year are in an FQHC or RHC. The Medicaid registration system will allow for assignment of payment by a provider to any entity set up as a “pay to” entity in the provider’s profile.    (Top of Page)

     

Follow us on Facebook