The Promoting Interoperability (PI) Program (formerly the Medicaid EHR Incentiv Program) is limited to Eligible Professionals (EPs) for six years of participation, and Eligible Hospitals (EHs) for three years. The program provides incentive payments to EPs and EHs as they adopt, implement, upgrade or demonstrate meaningful use of certified EHR technology. According to the Stage 1 Final Rule, EHs wishing to participate in the PI Program must begin receiving payments for Program Year (PY) 2016 or an earlier program year. Additionally, they must receive a PY 2016 payment and will not receive payments after PY 2021. After PY 2016, EHs must have participated in the previous year to receive payments.
- Acute care hospitals (including critical access hospitals) must meet a 10 percent minimum Medicaid patient volume
- Children’s hospitals (cannot be pediatric wings of larger hospitals) are not required to meet patient volume thresholds
Acute care, critical access and children’s hospitals are the only hospital types that are eligible for the PI Program. Acute care and critical access hospitals must have a Medicaid (Title XIX) patient volume of at least 10 percent of their total volume to be eligible to receive incentive payments. Patient volume is defined by CMS as the percent of Medicaid Title XIX encounters to total hospital encounters for the same 90-day period. Children’s hospitals do not have to meet Medicaid patient volume requirements to receive incentive payments. Click here for more information about eligibility for hospitals.
Adopt, Implement, Upgrade & Meaningful Use
Meaningful use Eligible Hospital participants must adopt (acquire and install), implement (training), upgrade (expand functionality with new version, etc.) or demonstrate meaningful use of certified EHR technology during Year 1 of their program participation. In the two remaining years of their program participation, Eligible Hospitals must demonstrate meaningful use (i.e., how the technology moves beyond being a digital medical chart to a valuable tool to transform health care service delivery and improve health outcomes).
Certified EHR Technology
The PI Program requires that all EHR products and systems must be certified by the Office of the National Coordinator for Health Information Technology (ONC). For more information, visit the ONC website at https://chpl.healthit.gov/#/search.
By meeting all program requirements, Eligible Hospitals may earn an incentive payment based on a formula that includes an annual EHR base amount; a per-discharge amount and a transition factor for each year; a Medicaid share based on inpatient, non-charity care days; and an aggregate EHR payment amount. The aggregate EHR payment estimate, when approved by DCH, is the total incentive payment that will be paid out during three years of participation.
Eligible Hospitals may receive payments from both Medicare and Medicaid PI Programs. The exceptions are children's hospitals, which will qualify for Medicaid incentive payments only.
QualityNet Secure Portal
Beginning January 2, 2018, dually eligible hospitals and critical access hospitals (CAHs) attesting to CMS will submit their 2017 Meaningful Use attestations in the QualityNet Secure Portal (QNet). The Registration and Attestation System will continue to be available for Medicaid-only hospitals and CAHs after December 31, 2017. Click here for additional information or here for the QNet Secure Portal Enrollment and Login User Guide.
Dually Eligible Hospitals and CAHs
Beginning with CY 2019, if you qualify for both the Medicare and Medicaid Promoting Interoperability Programs, you are required to demonstrate meaningful use for the Promoting Interoperability Programs to CMS and not to your state Medicaid agency and will need to complete registration and attestation with CMS. The official Medicaid Program Interoperability User Guide for Medicaid EHs provide easy instructions for using CMS’ systems. CMS has provided helpful tips and screenshots to walk the user through the registration process. Also, it provides important information needed to successfully register and attest.
Medicare Hardship Exception Information
Eligible hospitals and CAHs may be exempted from the Medicare downward payment adjustment if they can show that compliance with the requirement for being a meaningful EHR user would result in a significant hardship. To be considered for an exception (to avoid a downward payment adjustment), EHs and CAHs must complete and submit a Hardship Exception Application. If approved, the hardship exception is valid for only one payment adjustment year. Eligible hospitals and CAHs would need to submit a new application for subsequent years and in no case may an EH or CAH be granted an exception for more than five years.
Medicare Hardship Exception Application
The period for EHs to submit hardship forms for the 2020 payment adjustment years has ended. More information on the Medicare Hardship Exception Application can be found here. For questions regarding the Hardship Exception Application, please contact the QualityNet help desk for assistance at firstname.lastname@example.org or 1-866-288-8912. Click here for additional scoring, payment adjustment, and hardship information.