MEDI-CAL EHR INCENTIVE PROGRAM UPDATES
Greenway Health EHR
In December 2018, Greenway notified users of its SuccessEHS, Intergy, and Prime Suite EHRs that some data reported for meaningful use (MU) attestations was incorrect. DHCS, following guidance from CMS, continued to accept Meaningful Use (MU) attestations from Greenway EHR users with the understanding that Greenway would subsequently provide software updates that would allow users to submit corrected data for 2018.
CMS recently announced that updated software for the Intergy EHR would be available from Greenway as of August 16, 2019. However, this software will be able to correctly report on only 23 CQMs. For a list of these CQMs click here.
Intergy EHR users who have already attested for 2018 will be contacted by DHCS to resubmit meaningful use data for 2018. Providers should report on 6 CQMs that are relevant to their scope of practice, but if reporting on CQMs not on this list, should report zeros for numerators, denominators and other data fields. Providers who did not attest for 2018 because of Intergy EHR reporting problems and who would now like to attest should contact DHCS at Medi-Cal.EHR@dhcs.ca.gov.
Greenway has announced that it will not provide software updates for the SuccessEHS or Prime Suite EHRs. Providers who attested for 2018 using these EHRs will be contacted by DHCS to withdraw their attestations. These providers will be able to attest for the 2019 and subsequent program years using other CEHRT. DHCS expects Intergy to be the only Greenway EHR capable of correctly reporting MU data for 2019 attestations, however providers should contact their Greenway representatives regarding the capabilities of their EHRs for 2019 attestations. DHCS will consider on a case-by-case basis allowing providers who used SuccessEHS or Prime Suite EHRs to resubmit meaningful use data for 2018 only using alternative, non-CEHRT software to report from their EHRs. The accuracy and validity of such non-CEHRT reporting software must be adequately demonstrated by the provider.
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DHCS anticipates that 2019 attestations will be available in the SLR on January 2, 2020 with the following criteria:
- Attestations for the 2019 program year will be available for Stage 3 only.
- All providers will be required to attest to a MU reporting period of at least 90 days.
- Providers do not have to use 2015 CEHRT for the entire year, but must use 2015 CEHRT for the entire MU reporting period.
- Providers that have not reported MU previously will be required to attest to a CQM reporting period of at least 90 days, and providers that have reported MU previously will be required to attest to CQMs for the entire 2019 calendar year.
- Only hospitals that successfully attested to MU in 2018 can attest for MU in 2019.
- Only professionals that successfully attested to AIU or MU in the past can attest to MU for 2019.
2019 Prequalification Lists
The clinic prequalification list is available and can be accessed here.
The prequalification list for professionals is available and can be accessed here.
DHCS is required to conduct audits of hospitals and providers who receive EHR incentive payments for AIU or MU. Hospitals and providers should retain documentation supporting their attestations for at least seven years in case of an audit.
Hospitals - DHCS began auditing hospital AIU incentive payments in September 2015. The EHR audits are scheduled in the same manner as the Medi-Cal cost report audits. To the extent possible, the EHR audits will be combined with the cost report audits to minimize disruption to the hospital’s operations and staff.
Based on recent clarification and approval received from the Centers for Medicare and Medicaid Services (CMS), DHCS revises its EHR Incentive Program auditing standards as described below. These changes will apply both retroactively and going forward.
Administrative bed days are counted as acute inpatient bed days when calculating the Medicaid Share.
Psychiatric and rehabilitation bed days and discharges with care occurring in beds that would be paid under IPPS for Medicare patients are counted as acute inpatient bed days and discharges. Psychiatric and rehabilitation bed days and discharges with care occurring in beds that would not be paid under IPPS for Medicare patients are not counted as acute inpatient bed days or discharges.
DHCS has also clarified its auditing standards for Nursery Bed Days as follows:
Nursery bed days and discharges for sick children with care billed under codes 172-174 may be counted as acute inpatient bed days and discharges. In the past, only nursery bed days billed under code 174 could be counted as acute inpatient bed days or discharges.
Hospitals that have already been audited will, if appropriate, receive revised audit statements reflecting these changes. Hospitals with pending appeals should consult with their legal counsel regarding the relevance of these changes to their appeals.
Professionals - DHCS recently began auditing the meaningful use attestations of selected professionals.