Indiana Electronic Health Records (EHR) Incentive Program
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Deadline for Eligible Professionals for EHR Program Year 2013
is february 28, 2014
The last day of the 2013 Program Year for the
Electronic Health Records (EHR) Incentive Payment for Eligible
Professionals (EPs) is the end of the calendar year, December 31,
2013. EPs are allowed a 60-day grace period to submit attestations
for the 2013 program year. Thus, the last day to attest for Program
Year 2013 is February 28, 2014.
Eligible Professionals May Attest to Meaningful Use for EHR
Program Year 2014 Beginning April 17, 2014
Indiana will begin accepting Program Year 2014 meaningful use
(MU) attestations for Eligible Professionals (EPs) April 17, 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 April 17, 2014. To ensure
that the upgrade has been completed, please do not submit your
attestation until April 17, 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 for meaningful use, all
Indiana Health Coverage Programs (IHCP) providers will have a
90-day reporting period within the calendar year for Program Year
For additional information, please contact the Indiana EHR
helpdesk at 1-855-856-9563, or send your inquiries to MedicaidHealthIT@fssa.in.gov.
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 eligible professionals (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
Demonstrating meaningful use
It's not enough to own Certified EHR Technology (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
- 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.
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,
The deadline for Eligible Hospitals (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.
Program Integrity Audit Guidelines
Indiana understands the importance of the requirement to
monitor, measure, verify, validate, and report activities related
to pre-payment validation and post-payment 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.
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 pre-payment validation, which includes
automated and manual steps, the following two basic validations are
- Validate that the provider is currently enrolled as an IHCP
- Validate that the provider is an eligible professional (EP) or
eligible hospital (EH)
The provider is contacted if supporting information is required
to resolve any discrepancies or if additional documentation is
The post-payment 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
post-payment 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 post-payment audits are performed.
Typically, post-payment audits begin with desk reviews followed
by field audits if a desk review does not conclude audit
determinations. Post-payment audits include but are not limited to
- A review of financial payments
- 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
Appeals Process Overview
The Family and Social Services Administration (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
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
Expanding the Statement of the
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
- Specific findings, actions, or determinations of the office;
- 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:
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
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
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 >
- 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
Once you are ready to register, take the following steps:
- Your registration and attestation with the CMS for the Medicaid
EHR Incentive Program needs to be completed before you attempt to
register with Indiana's EHR Incentive Program. On May 2, 2011, the
CMS added Indiana to the list of available states. To register,
visit the CMS EHR Incentive
Program web page at the CMS website.
- Review the EHR MAPIR User Guide:
- To register with Indiana's EHR Incentive Program, access the
registration and attestation system through an active link on the
Provider Profile menu on Web interChange on this website. You must
be a Web interChange user
to access the Provider Profile menu.
Indiana State Medicaid Health Information Technology Plan
Click here to access
the most recent version of the Indiana State Medicaid Health
Information Technology Plan.
Recipients of IHCP EHR Incentive Program
Indiana is following the CMS' lead in posting the names of
Medicaid-eligible professionals (EPs), eligible hospitals (EHs),
and critical access hospitals (CAHs) that have successfully
demonstrated meaningful use and received payments: