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Frequently Asked Questions (FAQ) S.C. Medicaid Promoting Interoperability Program

REGISTRATION AND ATTESTATION

 

Q. How do I attest for the S.C. Medicaid Promoting Interoperability Program? What is the South Carolina Medicaid State Level Repository (SLR)?

A. The SLR is a system designed for Eligible Professionals (EP) and Eligible Hospitals (EH) that are registered in the CMS Registration and Attestation System for the S.C. Medicaid Promoting Interoperability Program to attest to meeting the Program requirements. If you have not already registered or need to obtain your CMS registration ID to login to the SLR, visit the CMS Website. You must login to the SLR www.scdhhs.gov/slr to attest for the S.C. Medicaid Promoting Interoperability Program.

Q. I have registered with the CMS Registration and Attestation System as an Eligible Professional who intends to attest with the South Carolina Medicaid program. Do I need to wait until the S.C. Medicaid Promoting Interoperability Program contacts me to begin attestation?

A. No. If you have made changes to your CMS Registration since submitting your attestation, you need to make sure you submit your changes at the CMS Registration and Attestation, or your attestation will not be able to be processed until you login and submit. If you have problems logging into the SLR, please contact us at HITSC@scdhhs.gov.

Q. If an attestation is submitted in the SLR, and the provider realizes that an error has been made, is it possible to change the attestation?

A. Yes. If the provider, or their representative needs to make a correction, the provider may e-mail the HIT Division at HITSC@scdhhs.gov or by calling 803-898-2996 to request that the attestation be re-opened for modification.

ELIGIBLE PROFESSIONALS

 

Q. Are Optometrists eligible to participate in the S.C. Medicaid Promoting Interoperability Program?

A. Yes. South Carolina elected to allow optometrists to participate in the Promoting Interoperability Program.

Q: In order to participate in the Medicaid Promoting Interoperability Program, an Eligible Professional may not be “hospital-based.” Will I need to submit documentation with my attestation to support that I am not hospital-based?

A: A not-hospital based letter is no longer required. An EP will be considered a hospital-based EP if 90 percent or more of their Medicaid services are provided in the following two places of service (POS) codes for HIPAA standard transactions: 21 – Inpatient Hospital, 23 – Emergency Room. The statutory definition of hospital-based EP provides that, to be considered a hospital-based EP, the EP must provide ”substantially all” of his or her covered professional services in a hospital setting. To determine that a provider is not considered hospital-based, the HIT Division examines Medicaid fee-for-service and encounter claims for the year preceding the program year to determine if the provider’s claims activity indicates hospital-based status.

      EXCEPTION WHICH ALLOWS CERTAIN EPs TO RECEIVE INCENTIVES IF THEY WORK IN HOSPITALS
An EP who initially is considered hospital-based but who can demonstrate the following may be determined to be a nonhospital-based EP and thus be eligible to participate and receive incentive payments:

  • The EP funds the acquisition, implementation, and maintenance of Certified EHR Technology, including supporting hardware and interfaces needed for meaningful use without reimbursement from an eligible hospital, and
  • The EP uses such Certified EHR Technology in the inpatient or emergency department of the hospital (instead of the hospital's EHR Technology)

If the above is applicable, please contact the HIT Division as soon as possible for more information, or with questions. Don’t assume you or your providers are not eligible.

EP PATIENT VOLUME

 

Q. How does the S.C. Medicaid Promoting Interoperability Program define a group/clinic?

A. The S.C. Medicaid Promoting Interoperability Program defines a group/clinic as “a group of healthcare practitioners organized as one legal entity under one Tax Identification Number.”

Q. My clinic is considering using the group patient volume calculation option based on Needy Individual patient volume. We have two providers that worked in the clinic in 2017 but who are no longer employed. Can those two providers’ encounters be included in the patient volume calculation even though they are no longer employed with us?

A. When calculating group volume, the organization falling under the Tax Identification Number identified in the attestation in the group patient volume entry field, must use the entire TIN organization's patient encounters and not limit it in any way. In the example given, the clinic should include the two providers’ encounters in the group patient volume calculation ONLY IF these two providers were employed by the organization (TIN) during their selected 90-day patient volume reporting period.

Q. If my organization wants to calculate group/clinic patient volume, and we have multiple sites, would we calculate based on each site’s group encounters, or across the entire organization?

A. The S.C. Medicaid Promoting Interoperability Program defines group or clinic as “a group of health care professionals organized as one legal entity under one Tax Identification Number.” The calculation would be based on all locations that operate under that legal entity’s one TIN.

Q. When I am attesting to the S.C. Medicaid Promoting Interoperability Program, I am attesting to patient volume from a 90-day period from the year prior to participation year. However, now that I am attesting to Meaningful Use, and attempt to use a Meaningful Use EHR Reporting Period from the previous calendar year, I am getting an error message – why?

A. For patient volume, an Eligible Professional will attest to encounters from any continuous representative 90-day period in the preceding calendar year (FFY for an Eligible Hospital) ; or (effective with the 2013 Participation Year), any continuous representative 90-day period for the 12-month period that immediately precedes the attestation submission date.
When attesting for Meaningful Use, the EP or EH must report on a Meaningful Use EHR Reporting Period that is within the Participation Year.
For example: an EP attesting to Meaningful Use in the 2013 Participation Year will use a Meaningful Use EHR Reporting Period from 2013.

Q. Our clinic plans to calculate the clinic Medicaid patient volume for our selected 90-day period of January 1, 2012 – March 31, 2012 to offer to our EPs as a proxy for their own individual patient volume. We hired several doctors in August of 2012; are they allowed to use our clinic volume as a proxy for their own, even though they were not with the practice during the patient volume period?

A. An EP whose date of hire by a clinic/group falls after the 90-day period selected for the clinic/group patient volume calculation may utilize the clinic/group patient volume as a proxy for his or her own patient volume, as long as it is appropriate as a patient volume methodology calculation for the EP. Said differently, a newly hired EP who is able and available to see Medicaid patients may utilize the clinic’s calculated Medicaid patient volume as a proxy for his or her own. It is important to note for providers wishing to base an attestation on Needy Individual patient volume that, although it’s possible for a group to calculate Needy Individual patient volume to offer as a proxy for its providers to use, the individual EP must still individually meet the requirement of having practiced predominantly in an FQHC or RHC (as determined by practice activity in the previous calendar year).

MEANINGFUL USE (MU)

 

Q. How does a provider arrange to test with the SC Department of Health and Environmental Control’s Immunization Registry, Syndromic Surveillance, or Cancer Registries?

A. If you are attesting to being in active engagement with one or more of SCDHEC's registries to meet the Public Health Registry Meaningful Use requirement, you can contact them for information about: beginning registry engagement for meaningful use; you or your organization's current engagement status, and to request documentation of status to upload to your attestation. Certain EPs are able to exclude requirements pertaining to public health registry reporting and still meet meaningful use. Some examples include: the EP did not administer any immunizations during their EHR reporting period; or the EP does not administer immunizations. please contact 803-898-2996 for more information.

S.C. Public Health Registries' Contact Information:

Q. Can I attest to two specialized registries to meet the Objective 10 of meaningful use? How do I locate specialized registries that are related to my scope of practice?

A. Yes, you may attest to submitting clinical data to two or more specialized registries to meet the Objective 10 requirement. If you intend to meet Objective 10 in this manner, you DO NOT need to meet or exclude measures 1 or 2 of Objective 10 (you only need to entry the registries you submitted to in measure 3). Therefore, only select measure 3 from the table. You may search for specialized registries at this link https://patientregistry.ahrq.gov/.

PAYMENT

 

Q. How does the S.C. Medicaid Promoting Interoperability Program disburse Medicaid incentive payments to hospitals, since the aggregate payment amount is determined in the Eligible Hospital’s first participation year?

A. The Eligible Hospital aggregate incentive amount is disbursed, as the EH meets the Program requirements for each participation year: 50% in the first year, 40% in the second year, and 10% in the third year. It is important to note that in order to continue receiving the incentives, the EH must meet the Program requirements for each participation year.

Q. How will I know when my attestation to the S.C. Medicaid Promoting Interoperability Program has been approved and to expect payment?

A. Once the SCDHHS HIT Division reviews the attestation and determines the provider has met the Program requirements, a transaction is sent to the CMS Registration and Attestation System to request a duplicate payment check (since a provider is only allowed one payment per participation year) and to lock the provider for payment. When SCDHHS receives the response from CMS to proceed with payment, the incentives will be incorporated into the SCDHHS weekly payment schedule as a one-time credit adjustment. Payment will be made via electronic funds transfer (EFT); or, where the provider does not have EFT, by paper check. When HIT sends information to CMS to confirm the incentives have been disbursed, the S.C. Medicaid SLR will generate an email to the email address associated with the provider’s account with information about the payment and how to identify it in the remittance advice. Where multiple EPs have reassigned their incentives to one entity, that entity’s remittance advice will show the individual incentives as separate line items on the remittance advice.


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