Indiana Electronic Health Records (EHR) Incentive Program
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Eligible Hospitals Approaching EHR Program Year 2013 Deadline
of November 30, 2013
The last day of the Electronic Health Records
(EHR) Incentive Payment Program Year 2013 for Eligible Hospitals
(EHs) was the end of the federal fiscal year, September 30, 2013.
EHs 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 November 30, 2013.
Please contact the Indiana EHR helpdesk at 1-855-856-9563, or
send your inquiries to MedicaidHealthIT@fssa.in.gov for
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 Medicaid
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 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
meaningful use (MU) of their CEHRT are eligible to
receive incentive payments. The EHR Incentive Programs consist of
two stages of meaningful use, each with its own set of requirements
to demonstrate meaningful use. The stages of participation are as
- Stage 1 - First participation year: To
demonstrate meaningful use, 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 meaningful use, 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 meaningful use by
meeting Stage 1 requirements for the continuous 90-day
- Stage 1 - Third participation year: To
demonstrate meaningful use, eligible providers must meet the Stage
1 requirements for the full calendar year (365 days).
- Stage 2 - All participation years: To
demonstrate meaningful use, 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 Eligible Professional (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 date for EPs attestation submission to no
later than February 28, 2014.
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.
Office of Medicaid 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 Medicaid 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 attestation supporting documentation 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 where appropriate.
Please note that the CMS will conduct all "meaningful use"
audits for EHs. The following audit guidelines do not apply to that
When the Medical Assistance Provider Incentive Repository
(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 will be stored in the database. All the information
submitted by the provider will be analyzed to ensure consistency
with Medicaid data.
During the process for pre-payment validation, which include
automated and manual steps, the following two basic validations
will be made:
- Validate that the provider is currently enrolled as an Indiana
- Validate that the provider is an eligible professional (EP) or
eligible hospital (EH)
The provider will be contacted if supporting information is
required to resolve any discrepancies or if additional
documentation is needed.
The post-payment review procedures are designed to assist in
identifying 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 will
be utilized prior to post-payment audits being performed.
Typically, post-payment audits begin with desk reviews and
follow with field audits if a desk audit review does not conclude
audit determinations. Post-payment audits include but are not
limited to the following:
- A review of financial payments
- A review of the documentation supporting AIU and Meaningful Use
attestations. The documentation obtained will be specific to each
provider based on the type of documentation available. The
supporting documentation could include electronic as well as
Appeals Process Overview
The Office of Medicaid Policy and Planning (OMPP) has a process
in place for eligible providers to appeal provider eligibility
determinations and HIT EHR Provider Incentive Payments. The appeals
process is used to address provider appeals of payments, provider
eligibility determinations, and demonstrations of efforts to adopt,
implement, upgrade, or meaningfully use of 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 will not be permitted to
expand the appeal beyond the statement of issues with respect to
- 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 its 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 will determine
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 will be leveraged to recover the funds. An
accounts receivable (A/R) record will be created associated with
the appropriate provider and the payment identified as an
overpayment. Payment amounts will be 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 Indiana Medicaid for at least the past 90
- Verify that you are
potentially eligible for the EHR Incentive Program - Refer to
the CMS website or use the CMS Eligibility
Wizard at the bottom of the EHR FAQs page of
indianamedicaid.com 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 will be 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 Indiana Medicaid is correct and consistent.
- For registration, the CMS will use 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 Indiana Medicaid.
- Update your National Plan & Provider Enumeration
System (NPPES) information on the CMS website.
- Update your provider profile through Web interChange at
indianamedicaid.com 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 will need 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 at indianamedicaid.com.
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 Indiana Medicaid EHR Incentive
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: