Why Medicaid providers should

ADOPT
Uncovering the truth behind MU
2015 THROUGH PROGRAM END 12/31/2016
BY AMANDA R. KERTH

MEDICAID VS MEDICARE EHR INCENTIVES

FROM CMS.GOV

WHAT IS ADOPT?

For Medicaid providers participating in the Medicaid EHR Incentives

program, adopt means to purchase, acquire or secure access to a 2014 ONC
Certified software piece. So you prove to the government you have
purchased certified software.

Adopt is part of A/I/U which stands for adopt/implement/upgrade certified

technology. If an eligible professional adopts (buys) certified technology,
they are allowed to attest for Year One Adopt in the Medicaid EHR Incentives
program which pays $21,250.00 per provider.

This is the first step in the program and can not be skipped. Unlike Medicare
eligible providers who are required to report MU measures for Year One
incentives, Medicaid providers are not required to report MU measures for
year one.

What is ONC?

The Office of the National Coordinator for Health Information Technology

(ONC) is at the forefront of the administrations health IT efforts and is a
resource to the entire health system to support the adoption of health
information technology and the promotion of nationwide health information
exchange to improve health care. ONC is organizationally located within the
Office of the Secretary for the U.S. Department of Health and Human
Services (HHS).

In simple terms, the ONC is the brains behind the technology standards.

From: https://www.healthit.gov/newsroom/about-onc

WHAT IS 2014 ONC CERTIFIED

SOFTWARE?
The rules for 2014 ONC Certified software were published in October of 2012 in the Final Rule released by
CMS. In order for a software piece to be tested and receive an ONC Certification product ID, the software
must meet the following criteria as published in:
https://www.healthit.gov/sites/default/files/onc_regulations_faqs_-_7_april_2013.pdf

Question [9-10-012-2]: How many clinical quality measures (CQMs) must EHR technology be capable
of calculating in order to get certified?

Answer:

2014 Edition EHR Certification Criteria:

EHR technology may be separately tested and certified, according to applicable standards, to: (1)
capture and export CQMs (45 CFR 170.314(c)(1)); (2) import and calculate CQMs (45 CFR170.314(c)(2));
and (3) electronically submit CQMs to CMS (45 CFR 170.314(c)(3)). EHR technology may be tested and
certified to meet 45 CFR 170.314(c)(1) and/or (2) for only one CQM.

However, to meet the Base EHR definition: (BASE EHR DEFINITION FOR 2014 CRITERIA)

EHR technology designed for an ambulatory setting must be tested and certified to 45 CFR 170.314(c)
(1) and (2) for no fewer than 9 CQMs covering at least 3 domains from the set selected by CMS for
EPs, including at least 6 CQMs from the recommended core set identified by CMS. THIS IS WILL BE
IMPORTANT LATER.

AS AN EXAMPLE DENTRIX 8.0 HAS 9 AMBULATORY CQMS (6 FROM THE RECOMMENDED

CQMS) ACROSS 3 CQM DOMAINS AS REFERENCED ABOVE

LEGAL DEFINITION OF A/I/U USING 2014

ONC CERTIFIED SOFTWARE AS
PUBLISHED BY CMS IN THE FINAL RULE

The definition of AIU in 42 CFR 495.302 allows the provider to demonstrate AIU
through any of the following: (a) acquiring, purchasing or securing access to
certified EHR technology; (b) installing or commencing utilization of certified EHR
technology capable of meeting meaningful use requirements; or (c) expanding the
available functionality of certified EHR technology capable of meeting meaningful
use requirements at the practice site, including staffing, maintenance, and
training, or upgrade from existing EHR technology to certified EHR technology per
the EHR certification criteria published by the Office of the National Coordinator of
Health Information Technology (ONC). Thus, a signed contract indicating that the
provider has adopted or upgraded would be sufficient.

Capable of meeting meaningful use does not mean you are required to
attest for meaningful use using the software. It means you own 2014
ONC Certified software that has the ability to attest for meaningful use.

ADOPT BEFORE MU AS PUBLISHED

BY CMS IN THE WHITE PAPERS#2

Section II.D.7.b.(2), Pages 44503505: Adopting, Implementing or

Upgrading

Unlike the Medicare incentive programs, the Medicaid program allows eligible
providers to receive an incentive payment even before they have begun to
meaningfully use certified EHR technology. These providers may receive a first
year of payment if they are engaged in efforts to adopt, implement, or
upgrade certified EHR technology. In proposed 495.302, we define adopting,
implementing or upgrading certified EHR technology as the process by which
providers have installed and commenced utilization of certified EHR technology
capable of meeting meaningful use requirements; or expanded the available
functionality and commenced utilization of certified EHR technology capable of
meeting meaningful use requirements at the practice site, including staffing,
maintenance, and training.

CMS ADOPT FAQ

63) Under the Medicaid Electronic Health Record (EHR) Incentive Program, if a
provider adopts, implements or upgrades (AIU) certified EHR technology in their
first year, the provider will not have to demonstrate meaningful use in order to
receive payment; in the second year they will have to demonstrate MU for a 90
day period only. Whereas a provider that is already a meaningful user (APPLIES
TO MEDICARE PROVIDERS REFER TO PAGE 1 ) would have to demonstrate for a 90
day period the first year and subsequent years they would have to demonstrate
it for the full year. Is this correct?
This is correct.
Date Updated: 8/25/2010
ID # 10112
FROM: https://www.cms.gov/Regulations-andGuidance/Legislation/EHRIncentivePrograms/downloads/faqsremediatedandrevised.pdf

2014 ONC SOFTWARE EXAMPLE

DENTRIX 7.0 & 8.0

DENTRIX 7.0 & 8.0 CONT.

The screenshot on the prior page is taken directly from the Certified Health IT Product List.
http://oncchpl.force.com/ehrcert/progress

Now lets look at the language above the two products on the previous page. It states:

Your product(s) meet 100% of the minimum required Base EHR criteria, CQM domains,
and either inpatient or ambulatory CQMs. You can now obtain your CMS EHR Certification ID.
* Additional certification criteria may need to be added in order to meet submission
requirements for Medicaid and Medicare programs.
The highlighted statements may seem confusing at first. Let me explain. If you ADOPT you
must use software that meets the 2014 BASE EHR CRITERIA. Dentrix 7.0 and 8.0 meet 100%
of the minimum required Base EHR criteria. However, if you purchase the base EHR
software and you choose seek MU objectives (Additional certification may need to be
added). Dentrix offers a subscription that includes ePrescribe, Portal and MU to
accommodate clients seeking MU objectives and costs around $2,250 for the licenses.

REMEMBER YEAR ONE ADOPT

ADOPT (Medicaid Providers)

= 2014 ONC TECHNOLOGY
THAT MEETS (AT A MINIMUM)
THE BASE EHR REQUIREMENT
= $21,250.00 PER PROVIDER

WHAT IS MEANINGFUL USE OR MU?

Meaningful Use or MU is where a Medicaid provider that has already ADOPTED and
received initial funds elects to choose a 90 day period to begin attesting for the
$8,500 incentive.

IMPORTANT-Dont use the word MU around your software sales rep. This shows the
sales rep you dont know what you are referring to and gives them an opportunity to
sell you something you dont need and wont use. Use the word adopt. We know the
word adopt = $21,250. MU = $8,500 + HEADACHES AND ADMIN BURDEN.

Only after you have adopted and received the Year One Incentives for $21,250 per
provider, is when you would call a software sales rep and ask to turn on the MU
modules. Turning on the modules will be an additional cost not included in the base
EHR software. It will provide the eligible professional the appropriate license and
reporting functionality to apply for the Year Two MU objectives paying $8,500.

MU REQUIREMENTS FROM CMS.GOV

MU REQUIREMENTS NOT LISTED IN

MU REQUIREMENTS

What providers may not realize is the preparation that goes into Year Two MU for $8,500.

Youll need to sit down with a very knowledgeable EHR consultant that understands the
nature of your business, the exclusions you might qualify for and develop a strategy for
what menu objectives, core data sets and clinical quality measures best suite your
practice workflow. Look Im available, but I dont think you want the headache.

You have to have current HIPAA Security Risk Assessments on file.

You have to change the language in your intake forms to address reporting on certain
demographics criteria.

Your staff will need additional training to actually use the MU modules.

Youll need someone to monitor the data weekly and make necessary adjustments should
you fall short of meeting the objective.

On and on and on. Too many to list!

MEANINGFUL USE TASK MASTER FOR

SERIOUS USERS OF TECHNOLOGY
FROM CMS.GOV

AM I MU? IS MY SOFTWARE 2014?

STILL CONFUSED? THE TRUTH
BEHIND MU

When the software rules were published in October of 2012 in The Final Rule the
push for MU began like a frenzied shark feeding. Soon the terms adopt or A/I/U
became obsolete in favor of a trendier MU.

To further complicate the matter, around mid 2013 the CMS started using A/I/U as
part of meaningful use. CMS retrofitted the term MU to include a provider with a log
in to a system could potentially use the software in a meaningful way. So soon all of
the terms were being tossed around and merged and used out of context. Meaning
and connotation very quickly fell into the hands of EHR vendors looking to profit from
the confusion. Meanwhile, the ambiguity served the Federal Government in
advancing the federal initiatives. Remember, the program was designed to advance
the healthcare system and provide more accountability, data interoperability, patient
engagement, reduce fraud and ultimately create a greater health and wellness
outcome amongst other goals. If everyone is getting in and upgrading then the
program is moving forward.

CONFUSION CONT.

Are you MU? Well you need to adopt first. **REMEMBER IF YOU ARE
ADOPTING YOU ARE NOT REQUIRED TO TURN ON OR PURCHASE MEANINGFUL
USE MODULES BECAUSE YOUR BASE PRODUCT MEETS THE 2014 CRITERIA.
THE NEW AND IMPROVED PRODUCT UPGRADES SERVE NO PURPOSE UNLESS
YOU APPLY FOR YEAR TWO WHICH INVOLVES CHOOSING A 90DAY PERIOD TO
REPORT TO THE GOVERNMENT ON CLINICAL QUALITY MEASURES.

Is your software 2014 compliant? Probably. If youve upgraded your EHR

system in the last 2 years you are likely operating a 2014 ONC Certified (Base
EHR software). Ive listed some common software pieces that qualify on page
18.

If you dont see your system email me at mandy@ehrpayment.com and I

will gladly look that information up for you.

2014 ONC CERTIFIED SOFTWARE

EXAMPLES THAT MEET 100% BASE
EHR LETS ADOPT!
PRODUCT

AltaPoint Advanced EHR

VERSION

PRACTICE TYPE

CERTIFICATION
EDITION

VENDOR

CHPL PRODUCT NUMBER

2014 CMS ONC CERTIFIED EHR

CERTIFICATION ID#

Ambulatory

2014 AltaPoint Data Syste...

140181R00

1314E01QOBA1EAP

15

Ambulatory

2014 AltaPoint Data Syste...

140236R00

1314E01QOSXJEAR

Carestream Vue RIS

11.0.12.60

Ambulatory

2014 Carestream Health

140169R00

1314E01PGXVMEAT

Carestream Vue RIS

11.0.12.50

Ambulatory

2014 Carestream Health

CC-2014-747350-1

1314E01PPVEKEAJ

AltaPoint EHR

DentiMax EHR

Ambulatory

2014 DentiMax, LLC

140347R00

1314E01PQBWXEAN

20141216

Ambulatory

2014 Planet DDS, Inc.

01222015-2779-3

1314E01PUST2EAJ

Dentrix EHR

2014.1

Ambulatory

2014 U.S. HealthRecord, I...

02192015-2408-6

1314E01QAUK7EAP

Dentrix Enterprise

8.0 CE

Ambulatory

2014 Henry Schein Practic...

130106R00

A014E01KIVG4EAF

Dentrix Enterprise

Ambulatory

2014 Henry Schein Practic...

CC-2014-100033-1

A014E01N9REHEAR

Eaglesoft Clinician

8.4

Ambulatory

2014 Patterson Dental Sup...

06262014-1989-8

1314E01P4VDAEAB

MacPractice 2020 MU

Ambulatory

2014 MacPractice, Inc.

140106R00

1314E01RCO6PEAH

MacPractice 2020 MU

5.1

Ambulatory

2014 MacPractice, Inc.

140106R01

1314E01RCO6UEAH

MacPractice DC MU

Ambulatory

2014 MacPractice, Inc.

140106R00

1314E01RCO6UEAH

MacPractice DC MU

5.1

Ambulatory

2014 MacPractice, Inc.

140106R01

1314E01RCO6ZEAH

MacPractice DDS MU

Ambulatory

2014 MacPractice, Inc.

140106R00

1314E01RCO79EAH

MacPractice DDS MU

5.1

Ambulatory

2014 MacPractice, Inc.

140106R01

1314E01RCO79EAH

MacPractice MD MU

Ambulatory

2014 MacPractice, Inc.

140106R00

1314E01RCO7EEAX

MacPractice MD MU

5.1

Ambulatory

2014 MacPractice, Inc.

140106R01

1314E01QQ6V2EAJ

QSIDental CPS

V4.4

Ambulatory

2014 NextGen Healthcare

CC-2014-345777-11

1314E01RCO7JEAX

QSIDental Web

2.3.0

Ambulatory

2014 NextGen Healthcare

CC-2014-345777-9

A014E01MALYLEAN

8.4

Ambulatory

2014 Professional Economi...

05302014-3072-8

1314E01OTFAEEAR

Denticon

XLDent MU