Indiana Electronic Health Records (EHR) Incentive Program

Look for the New_Item icon to find the most recently added information.

Eligible Professionals May Attest to Meaningful Use for EHR Program Year 2014 Beginning May 1, 2014

Indiana will begin accepting Program Year 2014 meaningful use (MU) attestations for eligible professionals (EPs) May 1, 2014. The Medical Assistance Provider Incentive Repository (MAPIR) is scheduled to be upgraded to comply with Program Year 2014 changes, and this upgrade will be completed by May 1, 2014. To ensure that the upgrade has been completed, please do not submit your attestation until May 1, 2014, or after. Any EP Program Year 2014 attestation started in MAPIR before the upgrade is complete will be aborted and will have to be restarted after the system upgrade. Please note that all Indiana Health Coverage Programs (IHCP) providers that attest for MU during Program Year 2014 will have a 90-day reporting period.

For additional information, please contact the Indiana Electronic Health Records (EHR) helpdesk at 1-855-856-9563, or send your inquiries to MedicaidHealthIT@fssa.in.gov.

Interactive Presentation of Indiana's Meaningful Use Data Available New_Item

Indiana providers continue to make progress toward meaningful use of electronic health records technology. An Indiana-specific, web-based presentation of that progress has been developed using openly available Indiana Medicare and Medicaid MU attestation data. The presentation provides an overview of EHR adoption and MU progression in our state. This tool will help stakeholders access the latest information in an interactive, easy-to-leverage, graphic format. You can filter this data several ways, including by:

  • Dollars received
  • Bed count
  • Participation in Medicaid versus Medicare or both
  • And more!

For a visual presentation of Indiana's progress, please see the Indiana Meaningful Use Interactive Report, hosted by Social Health Insights at in.muprogress.com.

EHR Program Overview

Since May 2, 2011, the state of Indiana has been participating in the federal EHR Incentive Program, funded through the Centers for Medicare & Medicaid Services (CMS). The American Recovery and Reinvestment Act of 2009 authorizes the CMS to provide incentives for EPs and eligible hospitals (EHs) as professionals and hospitals adopt, implement, upgrade, or demonstrate meaningful use of certified EHR technology (CEHRT) (see EHR Incentive Programs on the CMS website at cms.gov).

The implementation of the EHR initiative is a major cornerstone in improving providers' access to health information, coordination of care, and health outcomes for IHCP members. In the first year, providers can receive an incentive payment for adopting, implementing, or upgrading EHR technology. Providers must demonstrate meaningful use in following years to receive incentive payments.

Demonstrating meaningful use

It's not enough to own CEHRT. Providers have to show they are using CEHRT in ways that can positively affect the care of their patients.

To demonstrate meaningful use (MU), providers must meet all CMS' objectives for this program. Providers able to demonstrate MU of their CEHRT are eligible to receive incentive payments. The EHR Incentive Programs consist of two stages of MU, each with its own set of requirements to demonstrate MU. The stages of participation are as follows:

  • Stage 1 - First participation year: To demonstrate MU, eligible providers must meet the Stage 1 requirements and report data for a continuous 90-day period during the calendar year (any consecutive 90 days from January 1 to December 31).
  • Stage 1 - Second participation year: To demonstrate MU, eligible providers must meet the requirements for the entire calendar year (365 days). (Note: If a provider's second participation year falls in 2014, the provider can demonstrate MU by meeting Stage 1 requirements for the continuous 90-day period.)
  • Stage 1 - Third participation year: To demonstrate MU, eligible providers must meet the Stage 1 requirements for the full calendar year (365 days).
  • Stage 2 - All participation years: To demonstrate MU, eligible providers must meet Stage 2 requirements for the full calendar year (365 days).

To learn more about the requirements, visit the Meaningful Use page at cms.gov.

Program Deadlines

The Indiana deadline for EPs to attest for any EHR Incentive Payment Program Year is the last day of the calendar year. A 60-day grace period is allowed following the last day of the calendar year. For example, the last day to attest for Program Year 2013 is December 31, 2013, with the 60-day grace period extending the submission date for EPs' attestations to no later than February 28, 2014.

The deadline for EHs to attest for any EHR Incentive Payment Program Year is the last day of the federal fiscal year (FFY). A 60-day grace period is allowed following the last day of the FFY. For example, the last day for EHs to attest for Program Year 2013 was September 30, 2013, with the 60-day grace period extending the date for EHs' attestation submission to no later than November 30, 2013.

Auditing

Program Integrity Audit Guidelines

Indiana understands the importance of the requirement to monitor, measure, verify, validate, and report activities related to prepayment validation and postpayment audits of providers participating in the EHR Incentive Program.

To ensure program integrity, Indiana Family and Social Services Administration (FSSA) Audit Services and the IHCP Finance team employ various methods, standards, processes, and procedures to perform the required audit tasks for the Indiana EHR Incentive Program to be in full compliance with the CMS regulations.

Providers must submit auditable data and documentation for the EHR Incentive Program registration and attestation process, and on request for validation and audit procedures. Providers are required to retain all documentation supporting attestation for a minimum of six years after each payment year.

Indiana FSSA Audit Services and the Health Information Technology (HIT) Audit Work Group are committed to use existing and successful Program Integrity and Fraud and Abuse Detection Audit policies, processes, and procedures, when appropriate.

Please note that the CMS will conduct all MU audits for EHs. The following audit guidelines do not apply to that process.

Prepayment Validation

When the MAPIR of the EHR Provider Incentive Payment system receives a transaction from the Medicare & Medicaid EHR Incentive Program Registration & Attestation System (R&A) indicating that a provider has registered for the Indiana HIT EHR Incentive Program, a transaction is stored in the database. All the information submitted by the provider is analyzed to ensure consistency with IHCP data.

During the process for prepayment validation, which includes automated and manual steps, the following two basic validations are made:

  1. Validate that the provider is currently enrolled as an IHCP provider
  2. Validate that the provider is an EP or EH

The provider is contacted if supporting information is required to resolve any discrepancies or if additional documentation is needed.

Postpayment Audits

The postpayment review procedures are designed to help identify recoupment indicators and other potential incorrect payments. EHs or EPs that received a Medicaid incentive payment are subject to a postpayment review in the form of a desk review or an on-site review. A provider selection process based on proven Medicaid stratification variables and risk assessment criteria is used before postpayment audits are performed.

Typically, postpayment audits begin with desk reviews followed by field audits if a desk review does not conclude audit determinations. Postpayment audits include but are not limited to the following:

  1. A review of financial payments
  2. A review of the documentation supporting adopt, implement, and upgrade (AIU) and MU attestations. The documentation obtained is specific to each provider based on the type of documentation available. This documentation could include electronic as well as hard-copy documentation.

Appeals Process Overview

The FSSA has a process in place for eligible providers to appeal provider eligibility determinations and HIT EHR Provider Incentive Payments. The appeals process addresses provider appeals of payments, provider eligibility determinations, and demonstrations of efforts to adopt, implement, upgrade, or meaningfully use CEHRT.

In accordance with 405 IAC 1-1.5-2(d), a provider that wishes to appeal a determination must file a statement of issues with the FSSA:

  • Within 45 calendar days after the provider receives notice of the determination of the office; or
  • At the time the provider files a timely request for appeal, whichever is later.*

*IC 12-15-13-3.5(e)(2) requires the provider to file an administrative appeal not later than 60 days after receiving the notice of the determination if the provider wants to appeal the determination. Therefore, the corresponding statement of issues would also be due at that time to be considered timely.

Content of the Statement of the Issues

In accordance with 405 IAC 1-1.5-2(e), the statement of issues shall set out in detail the following:

  • The specific findings, actions, or determinations of the office the provider is appealing; and
  • With respect to each finding, action, or determination:
    • Why the provider believes that the office's determination was in error; and
    • All statutes or rules supporting the provider's contentions of error

Expanding the Statement of the Issues

In accordance with 405 IAC 1-1.5-2(f), the statement of issues shall govern the scope of the issues to be adjudicated in the appeal under this rule. The provider is not permitted to expand the appeal beyond the statement of issues with respect to the following:

  • Specific findings, actions, or determinations of the office; or
  • The reason or rationale supporting the provider's appeal

Per 405 IAC 1-1.5-2(g), a provider may supplement or modify his or her statement of issues for good cause shown up to 60 calendar days after the appeal request is mailed to the office. The administrative law judge assigned to hear the appeal determines good cause. The appeal must be mailed to the following address:

MS07
Secretary Debra Minott
c/o Jennifer Jenvey
Office of Medicaid Policy and Planning
Indiana Family and Social Services Administration
402 W. Washington Street. Room W374
Indianapolis, IN 46204

Recoupment

If it is determined that monies have been paid inappropriately, a recoupment process is leveraged to recover the funds. An accounts receivable (A/R) record is created associated with the appropriate provider and the payment identified as an overpayment. Payment amounts are collected and refunded to the CMS via the appropriate adjustment.

Registering for the EHR Program

Before you register with Indiana's EHR Incentive Program, take the following steps:

  • Verify that the provider you are trying to register has been actively enrolled with the IHCP for at least the past 90 days.
  • Verify that you are potentially eligible for the EHR Incentive Program - See the CMS website or use the CMS Eligibility Wizard at the bottom of the EHR FAQs page of this website to answer a few questions to determine your potential eligibility for the EHR Incentive Program.
  • Make sure you have a certified EHR system − Check the Certified Health IT [Information Technology] Product List (CHPL) for the authoritative, comprehensive list of Complete EHRs and EHR Modules that have been tested and certified under the Temporary Certification Program on the Office of the National Coordinator (ONC) for Health IT website at hhs.gov > Recovery.
  • Update or verify your Provider Enrollment Chain and Ownership System (PECOS) information via the CMS website at cms.gov (Medicare > Medicare Provider-Supplier Enrollment > Internet Based PECOS > Access to internet Based PECOS).
  • Enroll in Web interChange if you have not already done so. Indiana's EHR Registration and Attestation portal is available to providers from within Web interChange, so make sure you can access this important tool. You can contact the Web interChange team via telephone at (317) 488-5160 or 1-877-877-5182; or via email at INXIXElectronicSolution@hp.com.
  • Make sure the information you have on file with the National Plan & Provider Enumeration System (NPPES) on the CMS website and with the IHCP is correct and consistent.
    • For registration, the CMS uses the information you have on file with the NPPES, including your National Provider Identifier (NPI) and tax identification number. When you register with Indiana's EHR Incentive Program, the CMS information must match information on file with the IHCP.
    • Update your National Plan & Provider Enumeration System (NPPES) information on the CMS website.
    • Update your provider profile through Web interChange on this website, or by contacting HP Provider Enrollment at 1-877-707-5750.

Once you are ready to register, take the following steps:

Indiana State Medicaid Health Information Technology Plan

Click here to access the most recent version of the Indiana State Medicaid Health Information Technology Plan.

More information?

Recipients of IHCP EHR Incentive Program Payments

Indiana is following the CMS' lead in posting the names of Medicaid EPs, EHs, and critical access hospitals (CAHs) that have successfully demonstrated meaningful use and received payments: