For an Eligible Provider (EP) to participate in the Medicaid EHR Incentive Program in 2020, the EP must utilize a single software application or combination of software programs that are certified for the full set of modules defined as Certified Health Record Technology (CEHRT). In addition, the EP must demonstrate adequate performance to the 2020 Automated Measures. Lastly, the EP needs to report their performance on a set of Clinical Quality Measures (CQMs).
All participants in the Medicaid Promoting Interoperability Program are required to use 2015 Edition CEHRT. The 2015 Edition CEHRT did not have to be implemented on January 1, 2020 but the functionality must be in place by the first day of the EHR reporting period and must be certified to the 2015 Edition criteria by the last day of the EHR reporting period. All EPs must report a minimum of 90 days for the 2020 Automated Measures and eCQMs.
For practices participating in the EHR Incentive Program, a live interface in production is not required to attest to the Public Health and Clinical Data Registry Reporting measure. The EP must be in active engagement, which according to CMS means that the provider is in the process of moving towards sending production data to a public health agency or clinical data registry. Active engagement can fall into one of three categories:
- Option 1 - Completed Registration to Submit Data:
The EP registered to submit data with the PHA or, where applicable, the CDR to which the information is being submitted; registration was completed within 60 days after the start of the EHR reporting period; and the EP is awaiting an invitation from the PHA or CDR to begin testing and validation. This option allows providers to meet the measure when the PHA or the CDR has limited resources to initiate the testing and validation process. Providers that have registered in previous years do not need to submit an additional registration to meet this requirement for each EHR reporting period.
- Option 2 - Testing and Validation:
The EP is in the process of testing and validation of the electronic submission of data. Providers must respond to requests from the PHA or, where applicable, the CDR within 30 days; failure to respond twice within an EHR reporting period would result in that provider not meeting the measure.
- Option 3 - Production:
The EP has completed testing and validation of the electronic submission and is electronically submitting production data to the PHA or CDR.
EHR Incentive Program Eligibility Criteria
All OP providers participating in the EHR Incentive Program will need:
- OP 20
- OP Patient Portal (new patient portal powered by Intelichart)
- Direct Messaging