FLORIDA AGENCY FOR HEALTH CARE ADMINISTRATION

Transcription

1 FLORIDA AGENCY FOR HEALTH CARE ADMINISTRATION STATE MEDICAID HEALTH INFORMATION TECHNOLOGY PLAN UPDATE NOVEMBER 1, 2014

2 Date: 11/1/14 Version: 4.0 ii

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4 Change Record Date Author Version Change Reference 11/23/10 The Agency Governance changes incorporated 11/23/10 The Agency 1.11 Governance changes incorporated 12/02/10 The Agency 1.12 Governance changes incorporated 2/16/2011 North Highland Addressing CMS edits and Agency feedback / revisions 3/01/11 3/7/2011 North Highland 2.14 Final Agency Edits 2/29/2012 Heidi Fo 3.0 Agency SMHP Update 6/1/2012 Heidi Fo 3.2 Revisions per 4/23/12 CMS letter 11/30/12 Heidi Fo 3.3 Amendments to Section C Administration and Oversight of the EHR Incentive Program and inclusion of post payment audit plan. 11/1/14 Heidi Fo 4.0 SMHP Update pursuant to the CEHRT Fleibility Rule 4

5 State Medicaid Health Information Technology Plan Update Addendum This addendum to the State Medicaid Health Information Technology Plan (SMHP) addresses anticipated program, system, and audit changes related to the Certified Electronic Health Record Technology (CEHRT) Fleibility rule. Florida s most recent update to the SMHP was submitted to the Centers for Medicare and Medicaid Services (CMS) 11/30/12 and approved 3/18/13. CMS published the final CEHRT Fleibility final rule on August 29, 2014 effective October 1, The rule provisions allow providers to meet meaningful use (MU) requirements with electronic health records (EHRs) certified to the 2011 or the 2014 Edition criteria, or a combination of both Editions for the 2014 EHR Reporting Period. The rule requires providers to report using 2014 Edition CEHRT for the EHR Reporting Period in 2015, and etends Stage 2 through Although enhanced federal financial participation is available for Medicaid Electronic Health Record (EHR) Incentive Program administrative costs, Florida is fortunate in that the structure of our contracts allows the new requirements to be met without additional epense or changes in contract scope. The areas of potential impact are the core registration and attestation system, Medical Assistance Provider Incentive Repository (MAPIR), the state level registration and attestation system (SLA), the audit vendor contract and the outreach vendor contract. State Medicaid Agency Policy Changes The final rule provides parameters defining acceptable reasons that providers were unable to fully implement 2014 edition CEHRT. Pursuant to these changes, a Certification Fleibility Option Form has been developed for providers to complete and upload with their application that includes the five reasons for the inability to fully implement. The form includes check boes as well as a free tet bo to provide details. Any reason checked or given as free tet must be fully eplained. The information provided on the form will be compared to the attestation reasons attested to in state level attestation system and repository (SLR). The SLR will include check boes for the five reasons 2014 CEHRT is delayed as allowed in rule and a free tet bo to provide additional information. These are the reasons that will be coded into the SLR. Software development delays Missing or delayed software updates Being able to implement 2014 CEHRT for part of the reporting period (not the full reporting period) Unable to train staff, test the updates system, or put new workflows in place due to delay with installation of 2014 CEHRT Cannot meet Stage 2 Summary of Care measures due to the recipient of their Summary of Care transmittal being impacted by 2014 CEHRT issues. The sending provider may eperience significant difficulty meeting the 10% threshold for electronic transmissions, despite the referring provider s ability to send the electronic document, if the intermediary or the recipient of the 5

6 transition or referral is eperiencing delays in the ability to fully implement 2014 Edition CEHRT. The following reasons are not sufficient to warrant attestation under the CEHRT Fleibility Rule: financial issues, inability to meet one or more measures, staff turnover and changes, provider waited too long to engage a vendor, refusal to purchase the requisite software updates, or providers who fully implemented 2014 edition CEHRT and can report in The prepayment review process will include validation of the verification documentation received from providers. Staff will determine if additional documentation is needed to prove that their delay in implementation of 2014 edition CEHRT availability is attributable to issues related to software development, certification, implementation, testing, or release of the product by the EHR vendor. Provider Registration and Attestation Florida has reviewed and updated the eligibility verification checklists for Program Year 2014 processing. Incentive program staffs, Florida s fiscal agent, Hewlett Packard (HP), and the MAPIR collaborative states, are working to update state registration and attestation system requirements for the CEHRT Fleibility Rule. The MAPIR Business Design document has been approved by the MAPIR steering committee consisting of leadership from all participating states. The core code will be tested in early December and released to participating states by the end of December. Florida will incorporate into the Medicaid Management Information System (MMIS), test and promote into production. The attestation tail will need to be etended through June 30, An will be sent to the CMS Regional Officer requesting an etension of the attestation tail period. The process to validate the EHR certification is a web service connection in the SLR to the Office of the National Coordinator s Certified Health IT Product List (CHPL). This call out verifies that the certification number is valid. The process continues with manual verification by program staff using the search feature on the Medicaid HiTech website to verify that the CEHRT entered matches the product the provider has identified in their application documentation. The options for attestation available to the provider will be driven by the certification number they have entered as detailed in the chart below. 6

7 Medicaid EHR Incentive Program Payment Administration Pre-payment validation of attestations will continue to ensure that providers meet the requirements prior to approving a payment. The current appeals process is sufficient to accommodate denials that occur as a result of not meeting requirements to attest under the requirements in the CEHRT Fleibility Rule. Audit & Program Integrity Post-payment audit procedures are updated annually prior to commencing the audit for the program year. The annual updates incorporate changes to the audit risk profile. For 2014 this will reflect Fleibility Rule requirements as well as any other changes due to findings in the prior program year s audits. Outreach, Collaboration, Support Florida has been conducting outreach activities related to the release of the CEHRT Fleibility Rule. These efforts involve updating the state website to include general information, materials, and links to national resources (such as links to specific pages on the Centers for Medicaid and Medicare Services website), as related to the CEHRT Fleibility Rule. Materials produced by Florida s Medicaid Electronic Health Record (EHR) Incentive Program outreach team include 7

8 CEHRT Fleibility Rule Tip sheets, Frequently Asked Questions (FAQ) documents, PowerPoint presentations, newsletters and webinars for providers. Webinars on the CEHRT Fleibility Rule have been developed and provided and will continue to be held periodically throughout the 2014 attestation period. Efforts to reach out to providers who have not started 2014 attestations are ongoing. Additional information is provided to stakeholders routinely and as requested. Meetings with Florida s Regional Etension Centers (RECs) occur twice monthly with one session devoted entirely to questions and answers. CEHRT Fleibility Rule outreach materials are included at events such as association meetings and provider workshops. Provider workshops are held across the state providing opportunities for stakeholders to further their understanding of the requirements. Contact with stakeholders is tracked through electronic communication, s to our central mailbo, calls to the contact center; webinar participants are provided answers, in writing, as a follow up to questions received at webinars. Tip sheets and FAQs are updated continually based on feedback from stakeholders in order to better address identified gaps in knowledge. An in-service training has been conducted with call center staff to prepare them for provider inquiries on the rule changes. Updated FAQ documents are available to the call center staff. An escalation process includes referring callers to program staff as needed. State-Based Performance Measures Florida s registration and attestation system, MAPIR, documents the CEHRT used for attestation. Information will be available that identifies Eligible Professionals (EPs)/Eligible Hospitals (EHs) that have delayed implementing 2014 Edition CEHRT attributable to issues related to software development, certification, implementation, testing, or release of the product by the EHR vendor. This information will be available after all payments have been made for the 2014 program year. 8

9 Fleibility Rule Changes Effective October 1, 2014 State Checklist - Implementation Status Subject Change Target Not In Complete Notes Date Started Process SMHP/IAPD Submit SMHP Addendum to CMS Nov.1, In Process 2014 Submit IAPD-U to CMS, if additional FFP needed NA Not Applicable General Policy Review/update policies as it may relate to the Complete Changes Fleibility Rule Determine parameters defining acceptable reasons that providers were unable to fully implement 2014 Edition CEHRT Systems/ Infrastructure Determine CEHRT verification process providers will use Review/update pre-payment verification documentation requirements Design system changes and develop system requirements Develop system changes Test system changes Determine if attestation tail period needs etended Nov 2014 March 2015 Outreach Implement outreach strategy for stakeholders Auditing Provide training for SMA staff/vendors that field phone/ questions from providers Update post-payment audit procedures to incorporate Fleibility Rule Review/update audit risk profile(s) to reflect Fleibility Rule X Developed a form for providers to complete and upload with their application. Providers will also enter reasons in the MAPIR SLR. CHPL and HiTEch Website Scope for system changes completed. Certification number will drive choices for attesting to meaningful use. Requirements developed. Changes to be implemented at SLR and available for test 3/15. Will need to etend attestation tail In-service training complete 10/11/14 Will be done prior to PY 2014 audits 9