State Medicaid HIT Plan and Templates for Implementation of Section 4201 of ARRA (CMS-10292)

OMB Approval Number: 0938-XXXX
State Medicaid HIT Plan

STATE MEDICAID HIT PLAN (SMHP)
(Note:

This template represents what we believe is likely to be included in an SMHP, based upon the
provisions in section 4201 of ARRA. However, readers should be aware that the agency intends to
engage in notice and comment rulemaking in order to implement the incentives program authorized
by section 4201. Therefore, the contents and requirements of this initial SMHP are likely to change
after publication of a final rule, and States’ plans will need to be modified accordingly.)

PURPOSE: The SMHP
should describe the
State’s Medicaid
incentive program and
how it will integrate
current and planned
Medicaid HIT assets and
ft within the larger State
HIT/HIE roadmap.

SCOPE: Section 4201 of the ARRA provides 90% FFP HIT Administrative match for
States to administer the incentive payments provided for under such section. Such
administrative match is contingent on the State demonstrating to the satisfaction of the
Secretary that it meets the following three requirements:

1.

It is using the funds provided for the purposes of administering the incentive payments
to eligible professionals and hospitals, including tracking of meaningful use by
providers;

2.

It is conducting adequate oversight of the program, including. tracking meaningful use
by providers; and

3.

It is pursuing initiatives to encourage the adoption of certified EHR technology to
promote health care quality and the exchange of health care information.

The SMHP should address all three areas. We have subdivided the last section (“initiatives
to encourage the adoption of certified EHR technology”) into three additional subsections:
As-Is, To-Be and SMHP Roadmap. We are particularly interested in how the States
anticipate, based upon a preliminary review of the Recovery Act, that they will make and
monitor provider incentive payments, , and how the SMAs’ plans will dovetail with other
State-wide HIE planning initiatives supported by the HHS Office of the National
Coordinator and others, including assets needed in support of the SMHP future goals.

TIME FRAME: The SMHP time horizon is the next five years through 2014, although States may discuss their plans
beyond 2014, if appropriate. We understand States have a better understanding of their current, near-term needs and
objectives, and that plans will change over time. For this reason, we will expect to receive annual updates, as well as asneeded updates, to keep CMS informed of the SMHP as it evolves, and States’ ability to meet their targets over the next
five years.

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OMB Approval Number: 0938-XXXX
State Medicaid HIT Plan

SECTION A:

While CMS intends to
engage in rulemaking in
order to implement
section 4201, States can
conduct a review of the
Recovery Act and
determine how they
believe they will
administer the incentive
payments provided for
under such section. This
includes specific actions
for defining and verifying
EPs’ (physicians, dentists,
nurse practitioners,
certified nurse midwives,
and certain physician
assistants), as well as
acute care and children’s
hospitals’ eligibility for
payments, It also
includes actions for
processing payments and
ensuring against
duplicative incentive
payments for those
professionals eligible
under both the Medicare
and Medicaid programs.

Administering Incentive Payments to Eligible Professionals (EPs)
and Hospitals

1. Met the relevant provider enrollment eligibility criteria, including:





Not hospital-based for EPs (except for those EPs practicing predominantly in an
FQHC or RHC).
Medicaid patient volume
Use of certified EHR technology
Satisfactorily demonstrated meeting Meaningful Use requirements.

2.

Successfully adopted, implemented, or upgraded to certified electronic health record
technology during their first year of program participation (for those EPs and hospitals
that have not met the MU requirements in Year 1).

3.

Commenced utilization of the certified electronic health record .

4.

Meaningful use of certified EHR technology, potentially including the reporting of
clinical quality measures.

5.

The systems that will be used to establish EP and hospital eligibility as well as to
communicate with CMS to ensure no duplicate payment of incentives between
Medicaid and Medicare.

6.

How EP and hospital questions regarding eligibility for the program will be addressed,
such as through call centers or other means.

7.

Modifications necessary to the MMIS or other systems to coordinate, track and
account for the incentive payments.

8.

Any potential plans to create a provider appeals process for disputes regarding: a)
incentive payments, b) provider eligibility determinations, and c) demonstration of
efforts to adopt, implement or upgrade and meeting meaningful use requirements.

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OMB Approval Number: 0938-XXXX
State Medicaid HIT Plan

SECTION B: Conducting Adequate Oversight of the Program, Including Tracking
Meaningful Use by Providers

Provide a description of
the methodologies and/or
processes the SMA
anticipates it will employ
to ensure adequate
oversight regarding:

1. Methodologies used to verify:


Use of certified EHR technologies



Meaningful use of information, potentially including the reporting of clinical
quality measures.

2. Methodologies to verify that provider information conveyed to the State is accurate and
verifiable. Provider information may include information such as NPIs, information on
efforts to adopt, implement or upgrade to EHR technology, or information on
meaningful use of such technology. States would determine whether they anticipate
EPs and hospitals conveying such information via attestations or through other means.
3. If the measures for meaningful use become more stringent over time, States should
explain how they would assure systems can accommodate different requirements
depending upon the year the EP or hospitals begin receiving incentive payments.
4. All Federal funding, both for the 100 percent incentive payments, as well as the 90
percent HIT administrative match, are accounted for separately for the HITECH
provisions and not reported in a commingled manner with the enhanced MMIS FFP re:


No amount higher than the 100% FFP incentive to be claimed by EPs/hospitals.



EPs may not claim the incentive payment from more than one program (Medicaid
or Medicare but not both) (Note: Hospitals may claim payment of incentives from
both Medicaid and Medicare consistent with the requirements in Section 4201 and
subsequent regulations).



Medicaid provider payments are paid directly to such provider (or an employer or
facility to which the provider has assigned payments) without any deduction or
rebate.



Medicaid payments paid to an entity promoting the adoption of certified EHR
technology, as designated by the state and approved by the US DHHS Secretary,
are made only if participation in such a payment arrangement is voluntary by the
EP and that no more than 5 percent of such payments is retained for costs
unrelated to EHR technology adoption , as described in the Statute.



All hospital calculations and hospital payment incentives are made consistent with
the Statute and regulation, as well as a methodology to verify such information.

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OMB Approval Number: 0938-XXXX
State Medicaid HIT Plan

SECTION C: Encouraging the Adoption of Certified EHR Technology to Promote Health
Care Quality and the Exchange of Health Care Information .
Goals/Objectives: To what extent are Health Information Technology and Health
Information Exchange ( HIT and HIE) activities currently underway, including but not
limited to Electronic Health Record (EHR) technology adoption, in your Medicaid
enterprise?

A.

1.

Stakeholders: What parts of your program are currently engaged in these activities
and what is the extent of their involvement? With what other entities do you have HIE
relationships, and what is the nature of these activities?

2.

MMIS/MITA: Please describe the role of your Medicaid Management Information
System/Medicaid IT Architecture (MMIS/MITA) in your current HIE environment
relative to your provider community, Medicaid clients, and trading partners.

3.

Provider EHR Adoption: What steps are you planning to take in 2009 to use the
provider incentives under Section 4201 to achieve your goals? How will you know
which providers are eligible? That they are using certified EHRs? That they will be
able to meet the draft Meaningful Use criteria? Please describe in detail.

4.

ONC’s State HIT Coordinator/Governance: What structures are currently in place to
facilitate HIT/HIE and EHR adoption currently? What role does the Medicaid agency
play? Who else is currently involved? Explain your relationship to the State HIT
Coordinator.

5.

Other: What other activities do you currently have underway that will likely influence
the direction of HIT, HIE and EHR technology adoption over the next five years?
Please describe. How will these existing assets be leveraged to achieve provider
adoption?

“As-Is” Landscape

Narrative Discussion

B. “To-Be” Landscape
Narrative Discussion

1. Goals/Objectives: Looking forward to 2014, what specific goals and objectives do you
expect to achieve? Be as specific as possible; e.g., 100% of all Medicaid-participating
acute care and children’s hospitals, primary care physicians and nurse practitioners will
meet the Meaningful Use criteria (as currently proposed), 75% of all dentists, and 50% of
all nurse midwives by 2014.
2. MITA/Enterprise Architecture: What will your system architecture look like by 2014
to support achieving the 2014 goals and objectives? Web portals? Enterprise Service Bus?
How will your providers interface with your program? With other medical professionals?
With their patients?
3. ONC’s State HIT Coordinator/Governance: Given what you know about governance
structures currently in place, what should be in place by 2014 in order to achieve your
goals and objectives? While we do not expect you to know the specific organizations will
be involved, etc., we would appreciate your discussing this in the context of what is
missing today that you think would need to be in place five years from now to ensure EHR
adoption and meaning use of EHR technologies.

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OMB Approval Number: 0938-XXXX
State Medicaid HIT Plan

B. “To-Be” Landscape
Narrative Discussion
(Continued)

C.

Roadmap

4. Other: Please feel free to discuss other issues you believe need to be addressed,
institutions that will need to be present and interoperability arrangements that will need to
exist by 2014 to achieve your goals.

1.

Provide CMS with a graphical as well as narrative pathway that clearly shows where
your Medicaid agency is starting from (As-Is) today, where you expect to be five years
from now (To-Be), and how you plan to get there. What are the key milestones,
dependencies and risks?

2.

How will you measure your program? What methodologies do you intend to use to
establish a baseline and period remeasurements of adoption?

Annual Measurable
Targets Tied to Goals

In short, CMS is looking for a strategic plan, and the tactical steps that SMAs will be
taking (to the extent they are known), as well as those SMAs believe will need to be taken in
the future, to achieve your goals. We are specifically interested in those activities SMAs
will be taking to make the incentive payments to your providers, and the steps they will use
to monitor provider eligibility including meeting Meaningful use criteria on an annual
basis for accuracy and timeliness. We also are interested in the steps SMAs plan to take to
support provider uptake of EHR technologies and the infrastructure the SMA, working with
others, will create, build or adopt to foster HIE between Medicaid’s trading partners
within the State, with other States in the area where Medicaid clients also receive care, and
with any Federal data bases SMAs believe useful in this regard.

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