Provider Notice issued 12/8/11

To: Participating Hospitals

Date: December 8, 2011

Re:  Upcoming Deadline for Eligible Hospitals and CAHs Participating in the Medicaid EHR Incentive Program

Illinois Healthcare and Family Services (HFS) would like to notify eligible hospitals and critical access hospitals (CAHs) of the approaching deadline for attestation for the Medicaid Electronic Health Record Provider Incentive Payment (EHR/PIP) program. The deadline for attesting to the Medicaid EHR/PIP program via the HFS Medicaid Electronic Data Interchange (MEDI Web site) for program year 2011 is December 31, 2011.

Important Attestation Details for Eligible Hospitals and CAHs that are eligible to apply for both Medicare and Medicaid Incentive Payments.

The Medicaid EHR Provider Incentive Program offers eligible hospitals (EHs) and critical access hospitals (CAHs) additional flexibility not found in the Medicare version of the incentive program. EHs have an option to receive their initial incentive payment before they meet the full Meaningful Use Stage 1 requirements. The Final Rule allows EHs and CAHs to demonstrate that they have adopted (e.g., acquired, purchased or secured access to), implemented (e.g., installed or commenced utilized of) or upgraded to certified EHR technology in order to qualify for their first Medicaid incentive payment. However, EHs and CAHs must submit an attestation to HFS applying for the initial payment under the Medicaid A/I/U option before they attest to Medicare that they meet the Stage 1 Meaningful Use requirements. Once an EH or CAH attests to Medicare that they meet the MU requirements, their Medicaid attestations become linked to their Medicare MU status. In other words, their Medicaid attestations must match their Medicare attestations for each payment year and their Medicaid attestations must be submitted after their Medicare attestations.

This has the following implications for Eligible Hospitals:

If you have not yet attested to Meaningful Use (MU) with Medicare:

1. You can attest to meeting the less stringent criteria of adopt/implement/upgrade for the Medicaid EHR/PIP program now.
2. In order to receive an incentive payment for Federal fiscal year (FFY) 2011 from Medicaid, you must attest via HFS MEDI by December 31, 2011.
3. If you achieve A/I/U status in a subsequent payment year (e.g., FFY2012), you have the option of submitting an attestation to HFS based on A/I/U status before you submit an attestation to Medicare based on having satisfied the Stage 1 MU requirements.

If you have already attested to Meaningful Use (MU) with Medicare:

1. You have waived your ability to attest to adopt/implement/upgrade (A/I/U) with Medicaid. Instead, you will be deemed a meaningful user for the Medicaid EHR/PIP program based on your successful MU attestation with Medicare.
2. In order to receive an incentive payment for Federal fiscal year (FFY) 2011 from Medicaid, you must attest via HFS MEDI Web site by December 31, 2011.
3. If you do not attest with HFS by December 31, 2011, and you have already submitted your initial attestation to Medicare in 2011, you waive the 90-day MU attestation period for Medicaid and must wait until you complete the 365-day MU attestation period for your second Medicare payment year before you can attest to MU with HFS for your first Medicaid payment (after October 1, 2012).
4. Note that the Medicaid attestation application does not currently look different for A/I/U or MU.

Following are example scenarios:

Scenario 1: Hospital A has not yet attested to MU with Medicare. On December 15, 2011, Hospital A attests to A/I/U with Medicaid via HFS MEDI Web site. HFS verifies that all other requirements are met and performs pre-payment validations. HFS will issue the Medicaid incentive payment to Hospital A for payment year 2011 sometime after February 1, 2012.

Scenario 2: Hospital B attested to MU with Medicare on September 1, 2011, for payment year 2011. On December 31, 2011, Hospital B attests to MU with Medicaid via HFS MEDI Web site. HFS deems Hospital B a meaningful user based on the MU measures received from Medicare and verifies that all other requirements are met and performs pre-payment validations. HFS will issue the Medicaid incentive payment to Hospital B for payment year 2011 sometime after February 1, 2012.

Scenario 3: Hospital C attested to MU with Medicare on September 1, 2011, for payment year 2011. On January 1, 2012, Hospital C accesses the Medicaid attestation application but cannot select payment year 2011 from the drop down menu on the Patient Volume tab and must wait until they can meet requirements for the 365-day MU reporting period before they can attest for payment year 2012. They cannot apply for their first Medicaid payment until they apply for their second Medicare payment - sometime after October 1, 2012.

Please note: The above issue does not apply to Eligible Professionals (physicians, dentists, nurse practitioners, etc.), because unlike hospitals, Eligible Professionals must choose between participation in the Medicare or the Medicaid incentive program.

Questions regarding this program can be submitted to: E-mail HFS EHR Incentive

Theresa A. Eagleson, Administrator
Division of Medical Programs

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