Frequently Asked Questions

MU Overview

Q. What is Meaningful Use?

A. Meaningful Use (MU) is using certified electronic health record (EHR) technology in a meaningful way. The ultimate objective of MU is to improve patient care. The Centers for Medicare and Medicaid Services (CMS) provides incentive payment programs for Eligible Professionals and Eligible Hospitals that adopt, implement, upgrade or demonstrate MU of certified EHR technology.

There are 3 stages of Meaningful Use:

• Stage 1: 2011 - 2012, collect and share data
• Stage 2: 2013 - 2014, advanced clinical processes
• Stage 3: 2015+, improved patient outcomes
• Additional requirements to demonstrate MU will be added in each successive stage

State Medicaid Programs

Q. Will state Medicaid programs have different MU requirements than the Medicare program?

A. The CMS Final Rule requires that measures reported for Medicare also be applied to Medicaid but may be supplemented with additional Medicaid-specific measures. Check with your State Medicaid Health Plan for state specific detail.

EHR Certification

Q. Is the Resource and Patient Management System (RPMS) EHR certified?

A: Yes. On 4/1/11, the Indian Health Service became the first Federal agency to have a certified EHR. In order to have the certified version of RPMS, sites must install the RPMS EHR (BCER version 1.0) with all applicable patches. The Application Checklist [PDF - 21KB] contains a complete listing of all patches necessary to qualify for the certified version of RPMS.–More information.

BNP National Site Tracker

Q. How do I install the BNP National Site Tracker?

A. The installation is a two-step process

1. Install the BNP package on the RPMS system where you want to run the patch status report. Tribal and Federal sites can also set up a patch status report since the system is open to all RPMS systems regardless of 638 or Federal status. The BNP software can be installed by downloading it from the BNP server – the RPMS component that contains the install notes and KIDS files.
2. To access site information, you will need the MU package reporting client. You can download one for Windows 2000/XP/7 or a Mac version. After installing the client, run it on your computer. There are different reports that can be run by site, by application and one specifically for MU requirements.

Q. How do I get my site to appear in the National Site Tracker?

A. In order for the site to show up on this system, you must install the BNP package on your respective RPMS system. The download contains instructions and notes for site managers to install the software on RPMS.

Q. What if my site is not appearing in the National Site Tracker after installing the BNP?

A. BNP requires a network connection to the OIT BNP server. BNP uses an http web service protocol. Please note that this is not a Web site. The RPMS server at the site needs to have an open connection on TCP/IP port 80 outbound to nhin.ihs.gov and seal6.ihs.gov. This must be allowed at the firewall level. If the port is not open/permitted when the site installs BNP, the site will need to re-run ^BNPENV from the programmer prompt. This will force an automatic update from the site immediately.

Q. What if my site has a last report date of more than 24 hours ago?

A. For sites that have installed BNP on their RPMS system, when you open the MU Site tracking Software on the workstation, you will see a "Last Report Date". If that date is more than 24 hours ago, it means that the site has not been properly set up. To remedy this situation, the site manager must go in and queue the BNP package to run EVERY 24 HOURS. This will solve the problem of sites that are not reporting on regular basis. If site managers need assistance to do this, they can run BNPOST from the programmer prompt and it will do it for them automatically. Then, they must approve the entry in to task manager.

Q. Why is C32 showing Red in BNP National Site Tracker?

A. There are 2 possible reasons:

#1 - C32 is not installed
#2 - C32 is installed but missing correct version number in the version field

How do I get C32 to show Black in BNP National Site Tracker after installation?

A. If, after the C32 is installed, it is still showing Red, please follow these workaround steps:

1) Log into RPMS roll and scroll
2) Select option 11 “FileMan” and press enter
3) At “Select VA FileMan Option”: 1, type Enter or Edit File Entries and press enter
4) At “INPUT TO WHAT FILE: TAXONOMY//” type the word package and press enter
5) At “CHOOSE 1-4:” type 1 and press enter
6) At “EDIT WHICH FIELD: ALL//” type current version and press enter
7) At “THEN EDIT FIELD: “press enter
8) At "Select PACKAGE NAME:” type BJMD and press enter
9) At “CURRENT VERSION: //” type 1.0 and press enter
10) Press F7 to exit.

Changes may not be immediate, BNP will reset after 24 hours.

Symantec EndPoint Encryption Software

Q. Since IHS has given free licenses for VanDyke. Will free licenses also be given for Symantec?

A. Licenses for Symantec EndPoint Encryption and VanDyke (software for AIX systems only) were purchased for IHS owned equipment only. If you are IHS, you will have both applications and licenses for free. If you are a Tribal program, you may have to purchase licenses depending on how your facility has managed its shares. However, IHS has recently purchased additional Symantec EndPoint Encryption Software licenses. Sites should contact the OIT Helpdesk (support@ihs.gov) to request additional information.

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Reporting Period

Q. Can the official EHR reporting period precede the date of EHR certification?

A. No, the EHR reporting period cannot start until after the Certified EHR Technology is installed.

Eligibility

Q. Who is an Eligible Professional for the Medicaid EHR Incentive Program?

A. Eligible Professionals under the Medicaid EHR Incentive Program include:

• Physicians (primarily doctors of medicine and doctors of osteopathy)
• Nurse practitioner
• Certified nurse-midwife
• Dentist
• Physician assistant who furnishes services in a Federally Qualified Health Center or Rural Health Clinic that is led by a physician assistant

Q. Who is an Eligible Professional for the Medicare EHR Incentive Program?

A. Eligible Professionals under the Medicare EHR Incentive Program include:

• Doctor of medicine or osteopathy
• Doctor of dental surgery or dental medicine
• Doctor of podiatry
• Doctor of Optometry
• Chiropractor

Q. Who is considered a hospital based Eligible Professional?

A. An Eligible Professional is considered hospital-based if 90% or more of his or her services are performed in a hospital inpatient (Place of Service code 21) or emergency room (Place of Service code 23) setting. Hospital-based Eligible Professionals are not eligible for incentive payments.

Q. What does an Eligible Professional have to do to qualify for the Medicaid Incentive Program?

A. An Eligible Professional must adopt, implement or upgrade to a Certified EHR to qualify for the Medicaid EHR Incentive program. The Eligible Professional must also have a minimum 30% paid Medicaid encounter volume (Medicaid paid all or part of the encounter bill) for their practice. Pediatricians must have a minimum of 20%

Q. What is an Eligible Hospital under the Medicaid EHR Incentive Program?

A: Eligible Hospitals under the Medicaid EHR Program include:

• Acute care hospitals (including CAHs and cancer hospitals)
• Children’s hospitals (no Medicaid Patient Volume requirements)

Q. What is an Eligible Hospital under the Medicare EHR Incentive Program?

A: Eligible Hospitals under the Medicare EHR Incentive Program include:

• "Subsection (d) hospitals" in the 50 states or DC that are paid under the Inpatient Prospective Payment System (IPPS)
• Critical Access Hospitals (CAHs)
• Medicare Advantage (MA-Affiliated) Hospitals

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CMS Registration

Q. Can a facility conduct a bulk upload of provider registrations?

A. CMS is not enabling bulk registrations but is allowing Third Party Registration which will allow another person at a facility to register on behalf of an Eligible Professional for Medicare. This function was enabled on 4/18/11. For Medicaid, Eligible Professionals will need to check with their respective states to see if the Third Party Registration is available.

Q. Where do Eligible Professionals register for the CMS EHR Incentive Program?

A. Eligible Professionals must register to participate in the CMS EHR Incentive program . Eligible Professionals can register for both the Medicaid and Medicare Incentive programs even though they may only participate in one program at a time. Eligible Professionals may change from one program to the other once during the incentive program.

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Performance Measures

Q. How many MU Performance Measures must Eligible Professionals meet in Stage 1?

A. Eligible Professionals must:

• Meet 15 core Performance Measures
• Meet 5 Performance Measures from a menu set of 10. At least one population and public health measure from the menu set must be met
• Report on 6 Clinical Quality Measures - 3 core or alternate core measures and 3 measures from the menu set (there are no performance targets)

Q. How many MU Performance Measures must Eligible Hospitals meet in Stage 1?

A. Eligible Hospitals must:

• Meet 14 core Performance Measures
• Meet 5 Performance Measures from a menu set of 10. At least one population and public health measure from the menu set must be met
• Report on all 15 Clinical Quality Measures (there are no performance targets)

Q. How can progress toward meeting the required MU Performance Measures be monitored?

A. To monitor your progress use the Stage 1 MU Performance Reports for Eligible Professionals and Eligible Hospitals/CAHs located on the MUR menu in PCC Management Reports.

EHR Reporting Period

Q. Can the official EHR reporting period precede the date of EHR certification?

A. No, the EHR reporting period cannot start until after the Certified EHR Technology is installed.

C32 - Continuity of Care Document/Record

Q. How do I meet the MU Menu Set Performance Measure- Transition of Care Summary: EP who transitions or refers their patient to another care setting/provider gives summary of care for >50% of transitions of Care/Referrals?
(Exclusion: EPs that have no referrals during the EHR reporting).

A. Print the Summary of Care record for all active referrals and give to the patient and/or receiving provider by accessing the RCIS tab to view a list of referrals, including those that have not had a C32 printed. Do one of the following to print a C32 document:

• Select the patient, click the Referrals tab, click the referral, and click the “Print C32 for Referral” button, or
• View a list of active referrals for which C32s need to be printed by running the “Active Referrals without a Printed C32” report from the Administrative Reports menu. Login to the RPMS EHR to print the C32 for a specific referral and provide the C32 document to the patient and/or receiving provider.

Q. When do I use the C32 print function found on the Referrals Tab?

A. C32 print function found on the Referrals Tab is used to print 1 or more referrals for a patient. This satisfies the Menu Set Performance Measure: Transition of Care Summary: EP who transitions or refers their patient to another care setting/provider gives summary of care for >50% of transitions of Care/Referrals. (Exclusion: EPs that have no referrals during the EHR reporting).

Q. When do I use the C32 Button in the RPMS EHR GUI?

A. The C32 button provides a Summary of Care record and is used to meet the Core Performance Measure: Electronic Exchange of Clinical Information: Perform at least one test of certified EHR technology's capacity to electronically exchange key clinical information.

Q. What is needed to meet the Electronic Exchange of Health information Performance Measure?

A. C32 application must be implemented and tested.

Q. How do I perform a test of the C32 document for Stage 1 Meaningful Use (MU) attestation?

A. See Process for Testing a C32 for Meaningful Use (MU) Requirements [PDF - 188KB]

Q. How do I meet the MU Core Performance Measure- Electronic Copy of Health Information: >50% of patients of the EP who request an electronic copy of their health information are provided it within three business days?
(Exclusion: EPs who have no requests for electronic copy of health information.)

A. Configure PCC Health Summary, Patient Wellness Handout, Discharge Summary, and Discharge Instructions within the EHR.

• Provide the information electronically to the patient, such as on a CD, an encrypted e-mail, thumb drive or .pdf file.
• Document in Release of Information (ROI) requests for electronic copy of health information (enter as Patient/Agent Request Type=Electronic).
• Document in ROI that information was provided electronically (enter as Record Dissemination =Electronic) and record the Disclosure Date.

Q. What is the HIE Viewer (formerly known as Universal Client)?

A. An application used to view a CCR (Continuity of Care Record) sent in from an outside provider. The HIE (Health Information Exchange) Viewer is NOT required for Stage 1 Meaningful Use, though is required for meeting EHR certification. It enables a receiving EP/EH to view a patients Clinical Information in human readable format.

Clinical Quality Measure

Q. How do I determine the data for hospital measures ED-1 and ED-2?

A. A detailed description can be found in this document - MU-CQM-Hospital ED-1 and ED-2 Attestation Instructions [PDF - 230KB]

Patient Volume - General

Q. What is the participation year for the Medicaid EHR Incentive Program?

A. The Eligible Professional participation year is the calendar year for which payment is applied. For hospitals, the participation year is the Federal fiscal year for which payment is applied.

Q. What is the qualification year for the Medicaid EHR Incentive Program?

A. The qualification year for Eligible Professionals is the calendar year immediately preceding the participation year. For hospitals, the qualification year is the Federal fiscal year immediately preceding the participation year.

Q. What time frame is used to calculate Patient Volume for Eligible Professionals and Eligible Hospitals?

A. For Eligible Professionals, encounters are counted during any consecutive 90 day period during the qualification calendar year (January 1st – December 31st). For Eligible Hospitals, encounters are counted during any consecutive 90 day period during the qualification fiscal year (October 1st – September 30th). The 90 days may not span multiple calendar or fiscal years.

Q. Will a report be provided for RPMS EHR users to help calculate Patient Volume?

A. Eligible Professionals and Eligible Hospitals that are using the Third Party Billing Package will be able to run the Patient Volume Reports.

Q. Will Commercial off the Shelf (COTS) users be able to use the Patient Volume Report created for RPMS EHR users?

A. Although the Patient Volume Report will not be available for COTS users, the logic can be shared upon request.

Q. Per CMS FAQ #10417, my tribal clinic is considered a Federally Qualified Health Center (FQHC) for the Medicaid EHR Incentive Program. So our eligible professionals (EPs) need to have 30% "needy individual" patient volume in order to qualify. I understand that needy individual encounters include encounters covered by Medicaid, the Children's Health Insurance Program (CHIP), a sliding fee scale or uncompensated care. My clinic receives Indian Health Services (IHS) funding which only partially offsets the cost of these encounters that are not covered by Medicaid or CHIP, but my clinic does not impose costs on these individuals and does not have a sliding fee scale, so how do I count them?

A. Since your clinic receives IHS funding, the encounters are not truly "uncompensated", but the encounters would be considered services furnished at no cost (even if your clinic does not have a sliding fee scale), and therefore can be counted towards needy individual Patient Volume for tribal clinic-based EPs applying for the Medicaid EHR Incentive Program

Q. When Eligible Professionals/Locum Tenens work at more than one clinical site of practice, are they required to use data from all sites of practice to support their demonstration of meaningful use and the minimum Patient Volume thresholds for the Medicaid EHR Incentive Program?

A. Per CMS, they consider these two separate, but related issues.

Meaningful use: Any Eligible Professional demonstrating meaningful use must have at least 50% of their of their patient encounters during the EHR reporting period at a practice/location or practices/locations equipped with certified EHR technology capable of meeting all of the meaningful use objectives. Therefore, States should collect information on meaningful users' practice locations in order to validate this requirement in an audit.

Patient volume: Eligible Professionals may choose one (or more) clinical sites of practice in order to calculate their Patient Volume. This calculation does not need to be across all of an Eligible Professional's sites of practice. However, at least one of the locations where the Eligible Professional is adopting or meaningfully using certified EHR technology should be included in the Patient Volume. In other words, if an Eligible Professional practices in two locations, one with certified EHR technology and one without, the Eligible Professional should include the Patient Volume at least at the site that includes the certified EHR technology. When making an individual Patient Volume calculation (i.e., not using the group/clinic proxy option), a professional may calculate across all practice sites, or just at the one site.

Patient Volume - Eligible Professionals

Q. What are the Patient Volume thresholds for Eligible Professionals?

A. There is a 30% Medicaid Patient Volume threshold for Eligible Professionals, excluding Pediatricians.

Q. What are the Patient Volume thresholds for Pediatricians?

A. Pediatricians may participate in the Medicaid EHR Incentive program if they have a 20% Medicaid Patient Volume threshold. Pediatricians with only a 20% Patient Volume will only receive 2/3 of the Medicaid Incentive payment. Pediatricians who achieve at least a 30% Medicaid Patient Volume will receive the full incentive payment.

Q. How will 1115 paid encounters be counted in the Patient Volume report for states that have an 1115 waiver in place?

A. RPMS counts 1115 waiver paid encounters just like Medicaid paid encounters. Normally, there is not a separate source of payment for 1115 waiver claims; payment is recorded as if the claim was paid by regular Medicaid funds.

Q. When a patient has multiple encounters on the same day with different providers; can all encounters be used for calculating Patient Volume?

A. Yes, multiple providers may include an encounter for the same individual seen by multiple providers on the same day. For example, it may be common for a Physician Assistant or a Nurse Practitioner to provide care to a patient, then for a physician to also see that patient. It is acceptable in circumstances like this to include the same encounter for multiple providers when it is within the scope of practice. When a patient has multiple encounters on the same day with different providers, all encounters may be used for calculating Patient Volume, assuming they meet the encounter definitions described above.

Q. When can Medicaid Patient Volume group practice rate be used?

A. Medicaid Patient Volume group practice rate can be used when all of the providers in the clinic (Eligible Professionals AND Non-Eligible Professionals) agree to use the group rate for calculating Medicaid Patient Volume. If one provider does not agree to use the group calculation, then everyone has to use the individual Patient Volume calculation. If the entire clinic reaches the 30% paid Medicaid encounter threshold, all Eligible Professional in the clinic will have met the threshold. Only the Eligible Professionals qualify for the incentive payment, even though other providers contributed to the Medicaid encounter volume.

Q. What is considered a Medicaid patient encounter for Eligible Professionals?

A. Medicaid encounters are non-ER outpatient encounters that are paid in full or in part by Medicaid.

Q. Are Eligible Professionals at FQHC/RHC/Tribal clinics able to use the Needy Individual calculation for Patient Volume?

A. The needy individual Patient Volume will be used for Eligible Professionals who work predominately at an FQHC/RHC/Tribal clinic. An Eligible Professional is considered to work predominantly at an FQHC/RHC/Tribal clinic when the FQHC/RHC/Tribal clinic is the clinical location for over 50% of all of the provider's total encounters for six (6) months in the previous calendar year.

Q. What is considered a Needy Individual encounter for Eligible Professionals practicing at FQHC/RHC & Tribal Clinics?

A. Needy Individual encounters will include all non-ER outpatient encounters paid in full or in part by Medicaid-insurance type 'D' (includes 1115 Waivers); CHIP-insurance type 'K' billed as either Medicaid or Private Insurance; Discounted (sliding fee scale) encounters; and Uncompensated care. The Patient Volume Report in RPMS will include Medicaid and CHIP encounters.

Q. How is Patient Volume for individual Eligible Professionals calculated?

A:

Q. How is Needy Individual Patient Volume for Eligible Professionals practicing at FQHC/RHC & Tribal Clinics calculated?

A:

Q. How is the group method calculated for all Eligible Professionals at a clinic?

A:

Patient Volume - Hospitals

Q. What are the Patient Volume thresholds for hospitals?

A. There is a 10% Medicaid Patient Volume threshold for hospitals.

Q. How is Patient Volume calculated for hospitals?

A:

Dental

Q. Is the dental EHR certified?

A. No. There are no certified dental applications at this time. The American Dental Association, which is planning to be the certifying body for electronic dental records, is working on functional requirements and certifying criteria. There is no projected completion date announced at this time.

Q. How can dentists participate in one of the EHR Incentive programs without the use of a certified dental EHR?

A. Dentists can capture data such as demographics, vital signs, problem lists, medication lists and medication allergies in a certified EHR. Dentists can also participate in the MU Incentive programs by using a certified EHR for medication order entry. Information entered into an electronic dental record that is not certified will not qualify to meet Meaningful Use Performance Measure requirements.

IHS Electronic Dental Record (EDR) visit data, such as demographics and vitals, is interfaced to the RPMS PCC database. The RPMS MU Performance Measures reports access this data from the PCC database and not the EDR database. When this procedure is followed, CMS has determined that no independent certification of the IHS/EDR is necessary to achieve Meaningful Use.

Q. Does Dentrix have plans to become certified for Meaningful Use?

A. Dentrix is working on Version 6.0 and plans to submit it for modular certification. There is no projected completion date announced at this time.

Q. Can dentists in the IHS system qualify for the Medicaid EHR Incentive Program? They use a “bolt on” interface to access the data in RPMS through their dental “front end” program.

A. If dentists enter the problem list, medication list, medication allergy data, etc. directly in the EHR (RPMS), they are using the EHR in a Meaningful way and should qualify. If they only enter the data in the dental “front end” package, it is not passed through to RPMS and this would not meet the Meaningful Use criteria.

Incentive Payments

Q. Are EHR incentive payments considered taxable income?

A. Yes. The recipient of the 1098/1099 is responsible for the taxes. When the Eligible Professional's tax status is tax exempt or if the Eligible Professional re-assigns the incentive payment to a facility and the facility has a tax exempt status, then the incentive payment is not taxable.

Q. Is it true that all I have to do to qualify for the Medicaid EHR Incentive program in year one is to attest that I am using a Certified EHR?

A. No, to receive a Medicaid EHR incentive payment, Eligible Professionals must adopt, implement, or upgrade to a certified EHR technology and must demonstrate that they meet 30% Medicaid Patient Volume from the previous calendar year (20% for Pediatricians).

Q. If the providers of a clinic are participating in both Medicare and Medicaid programs can they still use a group practice rate for all or does each Eligible Professional have to qualify at the 30% threshold on their own?

A. Qualifying as a group for Medicaid with sufficient Patient Volume does not mean that each provider must participate in the Medicaid program. It means that each provider who wants to go the Medicaid route will be allowed to participate.

Q. Are PAs eligible to participate in the Medicaid incentive program?

A. PAs are eligible when they are a Physician Assistant who furnishes services in a Federally Qualified Health Center, Rural Health Clinic, or tribal clinic that is led by a Physician Assistant.

Attestation

Q. What is Attestation?

A. Attestation is telling CMS that you have met or exceeded all minimum requirements for either the Medicare or Medicaid EHR Incentive programs.

Q. What is the process to attest to CMS for the Medicare EHR Incentive program?

A. According to the CMS Web site:

Medicare Eligible Professionals, Eligible Hospitals and critical access hospitals will have to demonstrate meaningful use through CMS' web-based Registration and Attestation System .

Q. What is the process to attest to CMS for the Medicaid EHR Incentive program?

A: For the Medicaid EHR Incentive Program, providers will use their state’s Attestation System. See the scheduled launch dates for the Medicaid EHR Incentive Programs .

Q. Can an Eligible Professional assign the attestation process to another staff member for Medicare?

A. Yes, for Medicare EHR Incentive Program, an Eligible Professional can designate a third party to register and attest on his or her behalf. There are several steps in the process including setting up an account with the CMS Identity and Access Management System (I&A) for the party doing the attestation.

Q. Can an Eligible Professional assign the attestation process to another staff member for Medicaid?

A. Check with your state to see what functionality will be offered.

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