NY Medicaid EHR Incentive Program

Meaningful Use (MU) Attestation

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

Note:

NYS has not yet begun accepting 2017 attestations via the MEIPASS system. Once the MEIPASS system is available for 2017 attestations, announcements will be posted on the website and sent out via the NY Medicaid EHR Incentive Program LISTSERV. Enrolling in the LISTSERV will ensure you receive notifications on any program changes, important deadlines, and attestation reminders.

1. Eligibility

Healthcare practitioners must meet all eligibility requirements before being able to attest as an eligible professional (EP) in the NY Medicaid EHR Incentive Program. The requirements include the following:

  • Must be an eligible professional (EP) type
  • Must meet the Medicaid Patient Volume threshold
  • Must not be a hospital–based provider

Contact NY Medicaid EHR Incentive Program Support for assistance with determining hospital–based status.

2. Participation Requirements

Eligible professionals (EP) participating in the NY Medicaid EHR Incentive Program must maintain all program requirements in each participation year. The requirements include the following:

  • Must be enrolled as NY Medicaid fee–for–service provider
  • Payee must be enrolled as payable NY Medicaid Provider
  • Maintain ETIN association either personally or with a group/hospital

Please visit the Participation Checklist for more information on program requirements.

3. Becoming a Meaningful User of Certified EHR Technology

To receive the incentive payment, an eligible professional (EP) 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.

To be a meaningful user:

  • At least 50% of an EP´s total outpatient encounters during the EHR reporting period must be at locations equipped with certified EHR technology (CEHRT).
  • An EP must report on MU data from all locations equipped with CEHRT during the EHR reporting period.
  • An EP supports information exchange and the prevention of health information blocking and engaging in activities related to supporting providers with the performance of CEHRT and successfully reporting the clinical quality measures selected by CMS to New York State.

EHR Certification

To achieve Meaningful Use, providers must have at least the 2014 Edition of Certified EHR technology. Providers can also use a combination of the 2014 & 2015 Editions or use the 2015 Edition exclusively.

Prior to the release of the IPPS final rule in August 2017, providers were required to adopt the 2015 edition for program year 2018. CMS finalized policies to allow healthcare providers to continue to use the 2014 Edition CEHRT for Program Year 2018. This policy is based on our ongoing monitoring of the deployment and implementation status of EHR technology certified to the 2015 Edition and feedback by stakeholders who requested more time for the transition process.

EHR Reporting Period

  • Meaningful use EHR reporting is based on the calendar year.
  • The 2016, 2017, and 2018 MU reporting period has been reduced from a full year to a continuous 90–day timeframe.

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 and 2018, providers may choose to meet Stage 3 instead of Modified Stage 2.
  • Stage 3 measures
  • For 2019 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, EPs must report on clinical quality measures (CQMs). The 2016 and 2017 CQM reporting period is a minimum continuous 90–day period.

  • For 2016, EPs must report on 9 (of 64) clinical quality measures (CQMs) that cover at least 3 National Quality Strategy (NQS) domains.
  • For 2017, EPs must report on 6 (of 53) clinical quality measures (CQMs) from any National Quality Strategy (NQS) domain, relevant to the EP's scope of practice.

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. Attesting to Meaningful Use

Eligible professionals (EPs) must submit their attestations online via the NY Medicaid EHR Incentive Program attestation portal. Additionally, a signed hard copy of the complete attestation must be submitted.

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.

Providers must retain all supporting documentation for attestations for no less than six years after each payment year. Examples of supporting documentation:

  • Date–stamped reports generated from the EHR system
  • Screenshots of the EHR system´s interface
  • Dated correspondence with the public health registries

For post–payment audit guidance, contact hitech@omig.ny.gov or visit the Post–Payment Audit Guidance website.

5. Pre–Payment Review

All Eligible Professional (EP) 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 EP´s attestation. This review occurs each year the EP participates in the NY Medicaid EHR Incentive Program.

Regardless of which patient volume methodology an EP selects in attestation, New York Medicaid performs an eligibility validation. During this process, an EP may be contacted to provide additional information regarding their attestation. Click here for more information about supporting documentation.

If additional information is needed, New York Medicaid will initially contact the EP via the email address registered with the Center for Medicare and Medicaid Services (CMS). However, New York Medicaid may also contact the EP 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 professional (EP) may be contacted at the email address registered with CMS. The EP 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 Professional´s (EP) 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 payments for Participation Year 1 are $21,250 ($14,167 for pediatricians demonstrating between 20% and 29.99% Medicaid patient volume) with five remaining incentive payments of $8500. The New York State Department of Health will report the incentive payment amount on the assigned payee´s IRS 1099 form for the year in which the eligible provider´s incentive payment was received. The payee may be the eligible provider or an entity that has a contractual arrangement with the provider. Payee information is assigned in the CMS Registration and Attestation System but can be confirmed by logging into MEIPASS.