Frequently Asked Questions

Yes. Under Stage 2 meaningful use, providers must provide patients the ability to view online, download, and transmit the patients' health information. CMS understands that for many providers, utilizing a PHR through a HIE will be the best way to achieve this objective. As such, CMS allows states to request funding for PHRs under the Medicaid EHR Incentive Program's guidelines for requesting HIE funding. The parameters for this funding are outlined in State Medicaid Director (SMD) Letter #10-016 and SMD Letter #11-004, which emphasizes the fair share and cost allocation principles. For a provider to use the PHR service via the HIE, the PHR technology would need to be certified as an EHR Module to meet the meaningful use objective's certification criterion. When reviewing a state's request for PHR funding, CMS will consider how the proposed PHR solution affects the state's entire HIE landscape and whether there are any other PHRs options in the state. CMS expects any proposed PHR solution to support providers and stakeholders throughout the state, and not just those who are eligible for the Medicaid EHR Incentive Program. This strategy will best promote sustainability by bringing in other payers and by avoiding the creation of silos.

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FAQ ID:92551

As State Medicaid Director (SMD) Letter #10-016 makes clear, states cannot use HITECH administrative funds on activities that could otherwise be funded with MMIS matching funds. That includes activities related to developing and implementing functionality to allow patients to download their data that is housed in the MMIS, because states could potentially use MMIS funds to create this functionality for claims or clinical data that is housed within the MMIS. It is CMS policy that MMIS funding is available for clinical decision support functionality that ties directly to the MMIS to reduce cost and improve outcomes. See 42 CFR 433 Subpart C, and State Medicaid Manual Part 11. Please note that MMIS funding would not be allowable for infrastructure outside the MMIS environment.

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FAQ ID:92556

Yes, states can utilize 90/10 HITECH administrative funding to update existing HIE infrastructure to align with new Federal HIE guidelines and requirements to exchange data with Federal agencies. For funding to be available for this purpose, the HIE infrastructure must be used to support Medicaid eligible providers in achieving meaningful use; for instance by supporting the achievement of the requirement to submit a summary of care record electronically for more than 10 percent of eligible transitions.

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FAQ ID:92561

Yes, states can utilize 90/10 HITECH administrative funding for the Medicaid EHR Incentive Program to upgrade existing Direct infrastructure, which supports eligible providers in achieving relevant meaningful use objectives, to align with ONC guidelines. For instance, states could use the funds to move from a single certificate for a Health Information Service Provider (HISP) to certificates being issued to each health care related organization in a HISP or a more granular component of an organization (e.g., by department or by individual).

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FAQ ID:92566

States wishing to continue the practice of disregarding parental income may do so by adopting coverage of a reasonable classification of individuals under age 21 under section 42 CFR 435.222. In this case, the "reasonable classification" would be pregnant individuals under age 21 (or under age 18, 19, or 20). The statutory income standard for this group would be based on the state's AFDC payment standard in effect in the state in July 1996. But if a state uses section 1902(r)(2) of the Act to disregard all income for this group, as has been done for other reasonable classifications of children (such as those in state foster care), there will be no determination of income required for eligibility, and MAGI-based income requirements will not apply.

To effectuate this option, states should submit a state plan amendment (SPA) to amend Attachment 2.2-A of the Medicaid state plan to cover a reasonable classification of pregnant individuals under age 21 under 42 CFR 435.222. The state should also amend Supplement 8a to Attachment 2.6-A to disregard all income for this new group.

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FAQ ID:92601

If these practices and health systems maintain the types of documentation described in the previous answer, FAQ45736, with respect to managed care organizations, attestation by the group or system would be acceptable. As previously noted, a physician actually must be practicing as an internist, pediatrician or family physician in order to be eligible for higher payment. Board certification does not always equate to practice characteristics. Therefore, attestation on the basis of information on board certification alone would not suffice.

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FAQ ID:93866

No. The attestation and eligibility are physician-specific. If a physician provides services both in a fee-for-service and managed care environment, they need only complete the process of attestation once in order to receive higher payment for all eligible services they provide. CMS expects all information on self-attestation to be fully available to the state, regardless of which party collected this information.

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FAQ ID:93871

States have the flexibility to count eligible services provided by a physician in neighboring states in meeting the 60 percent threshold, but are not required to do so.

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FAQ ID:93876

These services would not be subject to the minimum payment standard set in the rule because there are no RVUs and there is no conversion factor associated with them. Therefore, a Medicare-like rate cannot be developed. The state may continue to reimburse them at the current Medicaid rate but enhanced federal financial participation (FFP) will not be available for those services.

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FAQ ID:93881

No. Verification of current board certification is sufficient.

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FAQ ID:93886