Scope 5.3 – EP focused Stage 2 MU
Background:
The Medicaid EHR Incentive Program requirements will change for Program Year 2014. This scope document specifically addresses the changes needed for Eligible Professionals (EPs). Eligible Hospitals (EHs) was addressed in MAPIR 5.2 which is currently being programmed with a scheduled core release date of November 2013. Program Year 2014 for EPs begins on January 1, 2014 and ends on December 31, 2014. The scope of requirements contained in this document will be included in MAPIR 5.3 with a planned core code release date of February 14, 2014. It is anticipated that the changes with this release may be used for Program Year 2015 as well, assuming there are no mandated CMS changes to Meaningful Use in Program Year 2015. Use of MAPIR 5.3 in Program Year 2016 is dependent on the publication of Stage 3 Meaningful Use by CMS. Therefore, MAPIR 5.3 must have a flexible design which will allow the continued use of Stage 2 Meaningful Use in Program Year 2016 and beyond in the event that Stage 3 release by CMS is delayed. The scope will also consider proposed changes to the NLR interface with CMS.
NOTE: This is a draft document that was developed after the JAD sessions held on March 19 and 21, 2013. It will be updated at CMC on the 25th and at the Workgroup on the 27th and presented to the collaborative at the steering committee meeting on the 28th.
Definitions and General Requirements:
The following is a list of definitions and business requirements to support MAPIR 5.3.
1) Program Year 2014 for EPs begins on January 1, 2014 and ends December 31, 2014. Per current functionality in MAPIR, states may configure a grace period for Program Year 2014. Generally, the grace period is for 90 days. The grace period length is configurable for each state in MAPIR.
2) CMS has announced there will be changes to the NLR to support Stage 2 Meaningful Use. MAPIR 5.3 must support the NLR 13.03 changes tentatively scheduled for July 2013. Below is the Interface Control Documents (ICD) for NLR 13.03 as of 5-10-2013. HP is encouraged to check the following website for updates to the ICDs. http://www.medicaidhitechta.org/ResourceLibrary/NLRDocumentation.aspx
a) Health Information Technology for Economic and Clinical Health (HITECH) National Level Repository (NLR) Interface Control Document (ICD) For Interface C-5: NLR – State, Dually Eligible Hospital Attestation Data Final Version: 5.1 Last Modified: March 27, 2013
b) Health Information Technology for Economic and Clinical Health (HITECH) National Level Repository (NLR) Interface Control Document (ICD) For Interface D-17: NLR – State, Dually Eligible Hospital Cost Report Data FINAL Version: 3.1 Last Modified: March 27, 2013
c) Health Information Technology for Economic and Clinical Health (HITECH) National Level Repository (NLR) Interface Control Document (ICD) For Interface D-18: State—NLR, Incentive Payment Data FINAL Version: 8.1 Last Modified: March 27, 2013
3) All Meaningful Use periods will be a continuous 90 day reporting period entirely within Program Year 2014. Applications submitted during Program Year 2014 grace period must use a continuous 90 day reporting period entirely within Program Year 2014. The continuous 90 day meaningful use period applies to the EPs regardless of previous attestation periods in prior program years. For example, if an EP attested to meaningful use for a full year in Program Year 2013, the continuous 90 day reporting period applies in Program Year 2014. In Program Year 2015 and beyond, EPs will be required to report a full calendar year of Meaningful Use if the EPs have previously successfully attested to a continuous 90 day of Meaningful Use prior to Program Year 2015.
4) EPs applying for their first Payment Year in Program Year 2014 are still eligible to apply using adoption, implementation or upgrade (AIU) in lieu of attesting to meaningful use. The EP may also choose to attest to meaningful use for any continuous 90 day period beginning and ending entirely in calendar year 2014.
5) There are two stages of Meaningful Use in Program Year 2014 as listed below:
a) Stage 1 for Program Year 2014 is referred to as MAPIR MU Stage 1.2. Refer to item #15 and the attachments there within that specifically identify all Meaningful Use Measures.
b) Stage 2 for Program Year 2014 is referred to as MAPIR MU Stage 2.0. Refer to item #16 and the attachments there within that specifically identify all Meaningful Use Measures.
6) EPs will attest to a specific stage of meaningful use as displayed in the table below. Note AIU is not meaningful use and does not count as a year of meaningful use. In the table below, Stage 1-2012 refers to Meaningful Use Measures effective for Program Year 2012 and is notated as MU Stage 1.0. Stage 1-2013 refers to Meaningful Use Measures effective for Program Year 2013 and is notated as MU Stage 1.1. Stage 1-2014 and Stage 1-2015 refers to Meaningful Use Measures effective for Program Year 2014 and is notated as MU Stage 1.2. Stage 2-2014 and Stage 2-2015 refers to the Meaningful Use Measures effective for Program Year 2014 and is notated as MU Stage 2.0.
Program Year / 2011 / 2012 / 2013 / 2014 / 20152011 / AIU/Stage 1 / Stage 1-2012 / Stage 1-2013 / Stage 2-2014 / Stage 2-2015
2012 / XXXXXXXXXX / AIU / Stage 1-2013 / Stage 1-2014 / Stage 2-2015
2012 / XXXXXXXXXX / Stage 1-2012 / Stage 1-2013 / Stage 2-2014 / Stage 2-2015
2013 / XXXXXXXXXX / XXXXXXXXXX / AIU / Stage 1-2014 / Stage 1-2015
2013 / XXXXXXXXXX / XXXXXXXXXX / Stage 1-2013 / Stage 1-2014 / Stage 2-2015
2014 / XXXXXXXXXX / XXXXXXXXXXX / XXXXXXXXXXX / AIU / Stage 1-2015
2014 / XXXXXXXXXX / XXXXXXXXXX / XXXXXXXXXX / Stage 1-2014 / Stage 1-2015
2015 / XXXXXXXXXX / XXXXXXXXXX / XXXXXXXXXX / XXXXXXXXXX / AIU
2015 / XXXXXXXXXX / XXXXXXXXXX / XXXXXXXXXX / XXXXXXXXXX / Stage 1-2015
7) EPs are allowed to voluntarily bypass a program year or multiple program years after their initial year of participation. EPs always may attest to AIU in their first participation year. EPs will retain their eligibility for attesting to Stage 1 Meaningful Use for two years and attesting to Stage 2 Meaningful Use for two years. However, if there is an adjustment due to an audit finding (payment adjustment reason code 01) the EP loses that program year of eligibility. Further, when an adjustment due to a retraction (adjustment reason code 07) the EP does not lose that program year eligibility. Adjustment reason code will be added in MAPIR 5.1 scheduled for a core release on May 15, 2013. MAPIR will be required to calculate the correct payment year for all applications that have adjustments due to an audit or due to a retraction. There are two other adjustment codes currently in MAPIR. Adjustment code 02 is an adjustment due to an updated calculation data and adjustment code 03 is an adjustment due to a recoupment. Outside of MAPIR but in the NLR schema are three additional codes as listed below. Use of these additional codes will be evaluated in future releases of MAPIR.
a) Adjustment code 04 – ‘Adjustment without recoupment’
b) Adjustment code 05 – ‘Adjustment due to appeal’
c) Adjustment code 06 – ‘Incentive payment calculation appeal upheld’
8) MAPIR must allow for the entry of a state defined audit number. When an adjustment is created with an audit reason code 01, MAPIR functionality is required to allow the state’s administrator to enter an audit number. The audit number must match the audit number entered at the CMS HITECH Research and Support User Interface. The audit field should allow 10 alpha/numeric characters. MAPIR will not verify the number entered at the CMS HITECH Research and Support User Interface matches the number that is entered by the state administrators. Mismatched numbers will result in a failed D18 record.
9) MAPIR will default to the following meaningful use progression:
a) An EP must complete two years in Stage 1 (MU Stage 1.0, MU Stage 1.1 or MU Stage 1.2) before proceeding to Stage 2. An EP may choose AIU in their first Payment Year as described in item #3 above. If AIU is chosen in Payment Year 1, then Payment Year 2 and 3 must be at appropriate Stage 1 meaningful use applicable for the Program Year.
b) An EP who was an early demonstrator of meaningful use in Program Year 2011 will meet three consecutive years of Stage 1 Meaningful Use if they attested in Program Years 2011, 2012, a 2013. These EPs must attest to Stage 2 Meaningful Use in Program Year 2014.
c) The maximum number of payment years for Stage 1 Meaningful Use is two years (allowing for the exception of EPs who attested to Stage 1 in Program Years 2011, 2012 and 2013). The third year must be at Stage 2 Meaningful Use in 2014 if at least two of the previous attestation was for Meaningful Use (does not include AIU).
10) MAPIR must be configurable (defined as ‘State Stage Configurable Option’) at the state level to allow an EP to skip a lower stage of meaningful use and proceed directly to a higher stage of meaningful use. EPs are never permitted to attest at a higher stage of meaningful use and then attest to a lower stage in subsequent payment years. Examples are as follows when the State Stage Configurable Option is activated:
a) An EP would have a choice in their first payment year to choose AIU, Stage 1, or Stage 2 Meaningful Use.
b) An EP who attested to Stage 1 Meaningful Use with 90 continuous days in their first payment year may go directly to Stage 2 in their second Payment Year thus skipping Stage 1 Meaningful Use Full Year.
c) An EP may attest to Stage 2 Meaningful Use in their first payment year.
d) An EP who attested to Stage 2 in their first payment year may not attest to Stage 1 Meaningful Use in their second payment year.
e) Normally, EPs are allowed one 90 day meaningful use attestation (except with Program Year 2014). If the 90 day period was used in Program Year 2014 (or earlier), then the EP must attest to a full year in either meaningful use stage in Program Year 2015.
11) MAPIR must be configured to allow at least two or more years of meaningful use at Stage 2. Further, MAPIR must be designed to allow States to configure additional years of Stage 2 Meaningful Use attestation after the initial two years in the event that Stage 3 has a delayed implementation in Program Year 2016. The MAPIR enhancement for Stage 3 will be addressed in a future scope document.
12) MAPIR must be configured to allow a change in CQM requirements during a program year. CQMs in calendar year 2014 may not be directly related to a specific calendar year or a specific Program Year. For example, currently an EP may choose from 64 unique CQMs. The total number of CQMs may increase or decrease at any time. Thus, CQMs are not necessarily related to a full calendar year or a full Program Year. If CQMs change the CMC will review and prepare a recommendation to the Steering Committee on an implementation plan.
13) The MAPIR provider dashboard and flow will change in MAPIR 5.3. An additional enhancement to the dashboard is explained below:
a) Add the previous year(s) attestation history to the Provider’s (public) dashboard and to the MAPIR administrative detail view. That is, display AIU, Stage 1 MU 90 Days, and Stage 1 MU Full Year, as appropriate to the EP. The Attestation Phase panel currently displays ‘Meaningful Use’ and does not provide sufficient information for review of applications with multiple stages of meaningful use.
b) In addition to the current information displayed on the dashboard, a column will be added showing the stage of meaningful use that was attained in past paid applications by the same state.
c) The entry in the column will be blank for an initial state to state switch or an initial Medicare to Medicaid switch. The column will be populated with the appropriate stage after the administrator enters the appropriate MU stage. In subsequent program years the MU stage will progress based the current stage progress rule.
14) The user interface ‘UI 1 Confirm Provider Account’ will display the EP’s meaningful use attestation stage. The meaningful use stage displays will be determined by the state’s configuration as described in 9 and 10 above.
a) If the ‘State Stage Configurable Option’ is deactivated, then a provider will be directed to the stage of meaningful use that is required by current CMS rules. For example, in the first payment year, an EP will have the option to choose between AIU and Stage 1 but Stage 2 will not be an option.
b) If the ‘State Stage Configurable Option’ is activated, the EP may select which stage of meaningful use is used in their attestation. EPs who have completed two or more years of Stage 1 Meaningful Use may only select Stage 2. There will not be an option for Stage 1. EPs in their first payment year may choose Stage 1 or 2 Meaningful Use or AIU when applicable.
c) When an application is denied and the payment year is forfeited the associated meaningful use stage is also forfeited. This means that both the payment year and MU stage is advanced for the next applicable program year and payment year.
15) Stage 1 Meaningful Use (MAPIR MU Stage 1.2) will be as follows:
a) Core Meaningful Use consists of 13 measures. Core Measure 1 has two options for the EP to choose from. Excel file titled “EP 2014 Stage 1.2 Core MU Mock Ups.xlsx” shows the verbiage for the core measures. Each measure must have a title bar with the appropriate measure number and title.
b) Menu Meaningful Use consists of 9 measures and an EP must select a minimum of 5 measures. Excel file titled “EP 2014 Stage 1.2 Menu MU Mock Ups.xlsx” shows the verbiage for the menu measures. Each measure must have a title bar with the appropriate measure number and title. The tab ‘Exclusion Rules’ has three scenarios. Paragraph 35 has further information on the logic required for MU Menu Measure selection.