NON-FQHC Meaningful Use Registration Toolkit - Public
IMPORTANT: CMS has posted the following information regarding third party registration on their website
- Update regarding third-party registration: At this time there is no method available for a third party to register multiple eligible professionals for the Medicare and Medicaid EHR Incentive Programs. Beginning in May 2011, CMS plans to implement functionality that will allow an eligible professional to designate a third party to register and attest on his or her behalf. We will release detailed information about that process when it is available. States will not necessarily offer the same functionality. Eligible professionals should contact their state to see if there is additional information they will need to provide.
Please be aware that eligible professionals currently are not permitted to allow a practice manager or any other person to register in their place. Sharing your National Plan and Provider Enumeration System (NPPES) user ID and password with third parties can place your information at risk. Until CMS implements new functionality in May 2011, each EP should register himself or herself separately for the Medicare and Medicaid EHR Incentive Programs.
On the state side in California, there will be third party registration capabilities. If a clinic or health center wants to register their providers as a group, it would be prudent to wait until May when both CMS and California have third party registration capabilities. It’s at the providers discretion to allow a third party administrator to register him/her on the CMS side, but note that CMS is not sanctioning this action and advises against it.
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I. Instructions for the Meaningful Use Registration Tool Kit |
DISCLAIMER: The information in this tool kit is intended only to provide a general overview of the topics addressed. This tool kit is not intended to provide legal advice or to substitute for the guidance, counsel or advice of legal counsel on any matters particular to a specific primary care clinic.
DO NOT COPY OR DISTRIBUTE the contents of the Registration Tool Kit to anyone outside of your clinic or health center.
The following material is meant to assist clinics when preparing and registering for Medi-Cal meaningful use incentive payments on behalf of their providers. CPCA recommends that at least one person at the clinic review all the material in the Tool Kit, and then determine the key staff at the organization to handle the various aspects of meaningful use. CPCA encourages the user of the Tool Kit to adapt the resources as is appropriate for his/her organization.
II. Fast Facts
This document is intended for a CEO/ CIO/ CMO or other management that is overseeing the meaningful use incentives program at the clinic. It contains the most relevant information related to meaningful use and applying for a payment for stage 1.
III. Readiness Check List
This document is intended for a CEO/ CIO/ CMO or other management that is overseeing meaningful use incentives program at the clinic. The checklist is an attempt at an exhaustive list of items and data necessary for applying and receiving meaningful use incentive payments. It is likely that more than one management level position at the organization will need to review this document and coordinate an appropriate process.
IV. CEO Script
This section contains a suggested framework of talking points and elements to include when a CEO or a CMO approaches their providers about the incentive payments and reassigning the payment to the clinic. CPCA created the elements in the script to be tailored to a conversation or a letter. Each CEO/CMO should determine which elements make the most sense to include in their conversations with providers. Key provisions of the meaningful use rule that would be applicable for providers can be found in the “Basics for Providers” Section V.
V. Basics for Providers
This fact sheet is meant to accompany communication the CEO or CMO has with providers about meaningful use. It is an attempt to distill the meaningful use information down to what a provider would be interested in and what is relevant to him/her.
VI. Registration Organizer
The Registration Organizer outlines all the information a clinic will need in order to register for the meaningful use incentives, either as a group or assisting their providers register individually. There are eligibility workbooks on the Medi-Cal EHR Provider Incentive Portal (ePIP) web page that the FQHC representative should also review. These can be found in the lower right hand corner in the “Downloadable Resources” box at http://medi-cal.ehr.ca.gov/. There are workbooks for both an EP and a Group.
IMPORTANT: CMS has posted the following information regarding third party registration on their website
“UPDATE regarding third-party registration: At this time there is no method available for a third party to register multiple eligible professionals for the Medicare and Medicaid EHR Incentive Programs. Beginning in May 2011, CMS plans to implement functionality that will allow an eligible professional to designate a third party to register and attest on his or her behalf. We will release detailed information about that process when it is available. States will not necessarily offer the same functionality. Eligible professionals should contact their state to see if there is additional information they will need to provide.
Please be aware that eligible professionals currently are not permitted to allow a practice manager or any other person to register in their place. Sharing your National Plan and Provider Enumeration System (NPPES) user ID and password with third parties can place your information at risk. Until CMS implements new functionality in May 2011, each EP should register himself or herself separately for the Medicare and Medicaid EHR Incentive Programs.”
On the state side in California, there will be third party registration capabilities. If a clinic wants to register their providers as a group, it would be prudent to wait until May 2011 when both CMS and California have third party registration capabilities. It’s at the providers discretion to allow a third party administrator to register him/her on the CMS side, but note that CMS is not sanctioning this action and advises against it.
VII. Contract Template
The contract template was created by CPCA legal counsel, Lawrence B. Garcia with Gordon and Rees LLP, and is meant to serve as a template for clinics or health centers looking to revise contracts with their providers. This contract template is not a substitute for the guidance, counsel or advice of legal counsel on any matters particular to a specific primary care clinic.
VIII. Dentist Crosswalk
Fortunately dentists are eligible professionals in the Medicaid Meaningful Use Incentive Program; however, there are barriers to their robust participation. In the first year, dentists at clinics can attest to A/I/U, however in the second years when reporting is mandatory it becomes more difficult because a dentist must use a certified EHR to participate. There are no standards by which to certify electronic dental records (EDRs), and thus no certified EDRs. Further there are no oral health measures in Stage 1 meaningful use for dentists to capture. The crosswalk is a tool for dentists at clinics to use in understanding meaningful use and how they can participate.
IX. Stage 1 Clinical Quality Measures and Functional Objectives and Measures
The measures for Stage 1 meaningful use are included as a reference.
To note, there are overlaps with meaningful use Stage 1 measures and UDS measures, as well as NCQA Patient Centered Medical Home 2011 criteria.
If you have any questions, or need more information, please contact Andie Patterson, Deputy Director of Regulatory Affairs, at apatterson@cpca.org.
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