Transcription:

Alyne Ellis (Host): MetaStar Health IT Radio is a podcast series that features consulting content experts and covers topics regarding the Wisconsin Medicaid EHR incentive program, Promoting Interoperability formerly Meaningful Use, as well as a Behavioral Health Technical Assistance Initiative. Episodes covered will guide your practice, clinic, hospital or hospital system through the complex federal state requirements of the PI program. MetaStar has helped more than 2000 providers attest to promoting inter-operability as Wisconsin's regional extension center since 2010, and continues to provide attestation assistance and audit preparation as a consulting service.

We're joined today by Chris Becker, a Project Specialist at MetaStar. I'm Alyne Ellis. Welcome Chris.

Chris Becker, CPHIMS, CPHIT (Guest): Yeah. Thank you. Thank you very much.

Host: So let's begin with what is the Wisconsin Medicaid Promoting Interoperability PI Program?

Chris: Right. Great place to start. The Medicaid Promoting Interoperability Program, formerly known as the Electronic Health Record Incentive Program, or a lot of folks still know it what as Meaningful Use. It was established as part of the American Recovery and Reinvestment act of 2009, and it was meant to encourage clinicians, eligible hospitals and critical access hospitals to either adopt, implement, upgrade, or demonstrate the meaningful use of certified electronic health record technology. The incentive payments for that program started in 2011 and now this program is going to sunset at the end of 2021.

Host: So, with 2021 being the final year for the program, are there any changes in the attestation process that participants need to be aware of?

Chris: Yes, there certainly are. Again with 2021 being the final year of the program. Per federal regulations, all incentive payments for it have to be issued prior to January 1st of 2022. After this date, the promoting Interoperability or PI program will be complete and no more payments will be issued. It will have run its course. This will significantly compress the timeline to meet all the program requirements as compared to previous years. The first notable change is that the Wisconsin Medicaid Promoting Interoperability Program will beginning accepting program year 2021 applications on April 1st, 2021.

This is in contrast to program year 2020 when the application process started on October 1st. The last day in eligible professional, or I'll refer it to moving forward as EP may submit a program year 2021 application is August 1st of 2021. When in previous years, the deadline was typically March 31st of the subsequent year.

So, for example, we're currently working on submitting 2020 program year 2020 attestations and we have until March 31st to get those in. But again, as I mentioned, that won't be the case this year because of that compressed timeline. This also means that the EP must choose any continuous 90 day reporting period between January 1st of 2021 and July 31st of 2021 for their EHR and electronic clinical quality measure reporting periods.

And just as a reminder, those 90 day periods for the EHR and ECQM or electronic clinical quality measure reporting periods don't need to be the same. They can be any consecutive 90 day period between January 1st and July 31st of this year. In past years, EPS were able to select those 90 day periods from within the entire calendar year. But again, you know, with that compressed year we've got those seven months to work with.

Host: Now I think that I heard there were some changes in regard to the PI objective number one, protect patient health information. Can you elaborate on that?

Chris: Yeah I sure can. A very important requirement. This requirement is to conduct a review, a security risk assessment or SRA. It's also changed due to the compressed reporting needs of the program year. Previously, the SRA must have been completed prior to the date of attestation. Now in program year 2021, EPS do not need to complete the SRA prior to the date of attestation, but it must be completed by the end of the day on December 31st, 2021. EPs who do not have the SRA completed by the date of attestation must attest to their intent to complete it by the end of the year or December 31st. And then upon completion of the SRA, the EP must submit the supporting documentation to a DHS secure email site and we'll have that link available and that information available on metastar.com/podcast and the transcript of this after the podcast here.

And they have to get that information in by January 31st, 2022. So, a little grace period into 2022, and then being that it is a required objective, EPs who do not complete these SRAs by December 31st and submit their SRA documentation by January 31st of 2022 are subject to audit and may have their incentive recouped.

Host: Are there any other significant changes that providers should be aware of?

Chris: Yes. One other item that I would mention is a change with regard to one of the public health reporting objectives. And I'm talking specifically about the syndromic surveillance registry. Prior to January 1st of 2021, Wisconsin Department of Public Health did not collect syndromic surveillance data from any category of eligible provider, unless that EP was already submitting data to the syndromic surveillance system. An example of that may have been, they may have been captured in as hospital feed, but normally they're not submitting data and EPs who were not submitting production data prior to January 1st of 2021, qualified to meet an exclusion that they did not operate in a jurisdiction where no public health authority has declared readiness to receive syndromic surveillance data.

Okay. So, for the purposes of testing to the syndromic surveillance reporting measure, all EPs are now required to at least register in the system. And that will satisfy that objective for 2021. Just maybe to highlight that a little bit or make that a little more, user-friendly that statement. So, in the past, they didn't have to register and could still get credit for it, but now they need to register in order to get credit for that. And again, those details are available on the Wisconsin DHS website. And we'll have a link to that information on the transcript of this podcast at metastar.com/podcast.

Host: So, how does one go about attesting to PI in Wisconsin?

Chris: For those folks that have been doing it, the process remains the same. They'll navigate to the Wisconsin Forward portal, which is ForwardHealth.Wisconsin.gov, and then they'll select the providers button and log into the Forward Health Portal. They'll then select the Wisconsin Medicaid PI program link, and then start the application per the Wisconsin Medicaid PI program user guide. And we'll provide that link to that user guide in our after podcast information.

Host: And what documentation do you suggest that providers and their staff have available when they're working through this application process on the Forward Health Portal?

Chris: Very important. DHS needs this information to see that one actually met the measures. So, the first pieces of documentation they'll need are proof of a certified EHR. They'll need to provide either a contract, a lease, proof of purchase receipt and or signed dated vendor letter to support the acquisition or use of 2015 edition CERT or Certified Electronic Health Record Technology.

And this documentation should include the vendor, product, product version number, indication that CERT was adopted and implemented or upgraded or in use during the program year, and then they'll need the certification ID. And that's provided by a CMS website called the Certified Health IT product list, otherwise known as the Chapel.

And we'll provide that link too if folks want to or need to look that up. The next piece of documentation is Medicaid patient volume documentation. So, whether they're attesting as an individual or a group, they'll need to provide that information to prove that they met the threshold, for seeing Medicaid patients to be included in this program. That documentation should include the provider NPI, the date of service, a unique patient ID, the financial payer, if it's Medicare, Medicaid, commercial or maybe out of pocket. And then we'll also note if there's any out-of-state Medicaid encounters. And finally we need the documentation from the actual objective.

So, these reports are typically known as Promoting Interoperability Objective Report. Also referred to as your dashboard, or I think some vendors probably haven't changed the language and it might be called the Meaningful Use Report yet. And that's needed to support all the PI percentage based measures such as e-prescribing, computerized physician order entry, health information exchange, and then we'll also need the security risk assessment report or documentation. And then finally, as a piece of the PI, we'll need the Clinical Quality Measure Report. And then at the end of the attestation process, all of the above documentation must either be uploaded to the Wisconsin Medicaid PI program, or if it's too large, we can securely email it to the Wisconsin Medicaid PI Program.

And again, details will be found on the Wisconsin DHS website that we'll provide a link to. And then one more thing, I just thought of, MetaStar has also created easy to follow application documentation checklist, and that's available on the MetaStar website and will again provide a link to that.

Host: So, how long after my application is submitted, will my clinic receive the incentive payment?

Chris: Normally in a normal year, it can take between 45 to 90 days for that application to be processed and payment to be issued. However, again, being that the program is sunsetting this year in 2021, all payments must be made by 12-31- 2021.

Host: And where would someone go for more information?

Chris: A really great source of information is the DHS website and that's DHS.Wisconsin.gov/ehrincentive and another is our MetaStar website, Metastar.com/healthitextension. And we'll provide those websites on the transcript of this on our medistar.com/podcast page.

Host: Well, thank you, Chris very much for detailing all this information about Wisconsin's Medicaid Promoting Interoperability PI Program. It was very interesting.

Chris: Yeah, you're welcome.

Host: Chris Becker is a Project Specialist at MetaStar. For more information on this topic and to access the resources mentioned, please visit metastar.com/podcast. That's M-E-T-Astar.com/podcast.