NY Medicaid EHR Incentive Program

Preparing for Meaningful Use (MU) Attestation

On 10/16/15, the Centers for Medicare and Medicaid Services (CMS) published a final rule that sets new criteria for eligible professionals and eligible hospitals participating in the EHR Incentive Programs.

The following steps outline a provider's path for attesting to meaningful use and receiving the incentive payment.

1. Maintaining Eligibility

Hospitals must meet all eligibility requirements before being able to attest as an eligible hospital (EH) in the NY Medicaid EHR Incentive Program.

The requirements include the following:

  • Must be an Acute Care or Children´s Hospital
  • Must meet the Medicaid patient volume threshold (where applicable)

2. Participation Requirements

Eligible hospitals (EH) attesting for Participation Year 2–3 (MU) of the NY Medicaid EHR Incentive Program must maintain all participation requirements.

The requirements include the following:

  • Must be enrolled as NY Medicaid fee–for–service provider
  • Must have an ETIN to maintain Medicaid Enrollment

3. Becoming a Meaningful User of Certified EHR Technology

To receive the incentive payment, an eligible hospital (EH) must become a meaningful user of certified EHR technology. Meaningful Use (MU) means providers need to show that they´re using certified EHR technology in ways that can be measured significantly in quality and in quantity.

EHR Certification

There are no changes to the certification requirements for 2015 through 2017. Providers must continue to use 2014 Edition of certified EHR technology (CEHRT). Optionally, providers may upgrade to 2015 Edition of CEHRT, but this is not required until 2018.

EHR Reporting Period
Effective 2015, meaningful use EHR reporting for hospitals has changed to the calendar year.

  • For 2015, MU has been reduced to a continuous 90-day EHR reporting period. EHs may select an EHR reporting period of any continuous 90-day period from October 1, 2014 to December 31, 2015.
  • For 2016, MU is a full calendar year. (Exception: Providers demonstrating MU for the first time would report for a continuous 90-day EHR reporting period.)

Objectives and Measures

The 2015 final rule removed the core and menu structure used in previous years. For 2015 and beyond, all providers are required to meet a single set of core objectives.

Modified Stage 2

Stage 3

  • For 2017, providers may choose to meet Stage 3 instead of Modified Stage 2.
  • 2017 Stage 3 measures
  • For 2018 and beyond, EPs must meet 8 core objectives and measures under Stage 3.

Additional Resources

Please visit our Public Health website or contact MUPublicHealthHELP@health.ny.gov for more guidance about the public health reporting objective.

Clinical Quality Measures (CQMs)

In addition to the required objectives and measures, EHs must report on 16 (of 29) clinical quality measures (CQMs) that cover at least 3 National Quality Strategy (NQS) domains.

  • For 2015 and 2016, CQM reporting is a continuous 90–day period.
  • For 2017, CQM reporting is a full calendar (except for providers demonstrating MU for the first time).

Alternate Attestation Method

Beginning in 2015, an EP unable to meet Medicaid patient volume may attest to meaningful use through the CMS registration and attestation system in order to avoid the Medicare payment adjustments. However, exercising this alternate attestation option does not switch the EP to the Medicare EHR Incentive Program, and the EP would not receive an incentive payment for that year.

4. Becoming a Meaningful User of Certified EHR Technology

How an eligible hospital (EH) participates in the Medicare and Medicaid EHR Incentive Programs determines the method of attestation. There are two ways to participate: a) as a dually–eligible hospital or b) as a Medicaid–only hospital.

  1. Dually–Eligible Hospital
    Dually–eligible hospitals will only need to attest to meaningful use once for both the Medicare and NY Medicaid EHR Incentive Programs. These hospitals will first submit their meaningful use attestation in the CMS Registration and Attestation System (for Medicare). CMS will then forward that attestation information to NY Medicaid, and the hospitals must finish the process in the NY Medicaid EHR Incentive Program attestation portal.
  2. Medicaid–Only Hospital
    NY Medicaid–only hospitals must attest at the state level through the NY Medicaid EHR Incentive Program attestation portal.

    The attestation must accurately reflect the meaningful use activities demonstrated by the provider during the EHR reporting period. It is recommended that providers save electronic files or print hard copies of the source documentation used at the time of attestation.

5. Pre–Payment Review

All eligible hospital (EH) applications for the NY Medicaid EHR Incentive Program are subject to review and approval to verify that the applicant has met program eligibility requirements. Following attestation and prior to payment, New York Medicaid performs a review of each EH's attestation. This review occurs each year the EH participates in the NY Medicaid EHR Incentive Program.

If additional information is needed, New York Medicaid will initially contact the EH via the email address registered with the Center for Medicare and Medicaid Services (CMS). However, New York Medicaid may also contact the EH via the phone number registered with CMS.

If at any time during pre–payment review there are questions regarding the process, please call the EHR Incentive Program Support Help Desk at 1–877–646–5410.

Pre–Payment Review:

  • An eligible hospital (EH) may be contacted at the email address registered with CMS. The EH contact should ensure that the email address registered with CMS is a valid email address and be sure to check it on a regular basis
  • Failing to respond to a program outreach may result in attestation rejection

6. Incentive Payment

The NY Medicaid EHR Incentive Program review timeline varies, as it is dependent on the volume of attestations and on validation failures. However, please note that attestations are generally processed in the order received, and every effort is made to expedite the review process so that payment can be made.

The eligible hospital's (EH) incentive payment will be disbursed as a lump sum payment in the weekly Medicaid payment run following CMS final approval. The incentive payment will be released using existing channels and processes for paying Medicaid fee–for–service providers.

Incentive payment amounts are unique to each EH and will vary based on hospital criteria including discharge volume and Medicaid bed days. To estimate your incentive payment, please use the Hospital Workbook.