States are experiencing a sense of urgency about preparing to uphold their end of the Medicaid meaningful use bargain, but not everything will be up and running as soon as the program begins next year.
States must implement the Medicaid health IT plans through which eligible providers will be able to receive payments from Electronic Health Records Incentive Programs (EHRIPs). The Centers for Medicare & Medicaid Services (CMS), the federal agency overseeing the meaningful use program, has to approve those plans. All states have received initial health IT planning grants from CMS, but they still are far from completing their final plans and obtaining CMS approval to implement them.
A recent report indicated that New Hampshire won't be ready for its Medicaid meaningful use program in 2011, the first year in which providers who participate in the meaningful use incentive plan will be eligible for funding. Officials there said they are moving forward with their health IT plan; however, they anticipate that approval for the plan's final implementation will not happen until later in 2011.
New Hampshire is not the only state grappling with the step-by-step process of establishing a health IT plan. Once states get initial planning approval from CMS, there still are several more steps. They must submit and receive approval for their draft plan. Once that is finished, states may work on their health IT implementation plan. States are eligible for CMS funding for their planning and implementation efforts as long as that agency has approved them.
Most states are still working on their health IT plan and have not moved on to implementation yet. There are a number of reasons for this, but mainly it's an issue of time, officials say.
"Everyone involved recognizes the timeline is very aggressive, but there's reason for that," said Ruth Carr, health IT coordinator for the state of Georgia.
Georgia is using a $5 million planning grant to finish its state plan, which it expects to submit to CMS in November, said Carr, who is leading the state's efforts to develop the Medicaid plan, along with a state health information exchange (HIE), another component of the meaningful use final rule.
When the plan is approved, Georgia can submit its implementation documents and begin to roll that technology out across the state to providers who want to participate in the incentive programs, Carr said. "Everybody needs the dollars and the economic boost. In terms of the urgency, it really is to get that activity going," she said.
Roughly 15% of Georgia's 10 million residents are covered by Medicaid. The state estimates that about 77 hospitals and 2,000 physicians will participate in the Medicaid portion of the meaningful use program. The state hopes to be in a position of allocating meaningful use incentives through Medicaid to eligible providers by the third or fourth quarter of 2011.
Key to Medicaid meaningful use effort: A national database
In addition to fine-tuning both the planning and implementing of technology, states are working with CMS to connect with a new database that will collect all the relevant provider information for the meaningful use program. States will have to use the CMS' National Level Repository (NLR) to communicate with the federal agency about whether doctors are eligible for the Medicaid portion of meaningful use, to ensure that no provider is trying to participate illegally and to determine that they are meeting the meaningful use criteria.
That communication itself has several steps. States will request information from the NLR, CMS will provide the information, states will verify that doctors can participate and CMS then will give the green light. Only then may states work on the actual meaningful use criteria and tell CMS that the doctors are meeting requirements before allocating incentive payments.
States have to demonstrate that their interfaces with the NLR can do all of that. The repository, however, is not finished yet. Defense contractor Northrop Grumman Corp. in May was awarded a one-year, $34 million contract to build the NLR. In June, Companion Data Services LLC received a $24 million contract to provide the repository's data processing and hosting operations.
A few states that have received the go-ahead on their health IT plans already, including North Carolina and Pennsylvania, will be part of a first round of testing with the NLR, expected to begin this month. More states will be part of a second test group that is slated to start in January or May of 2011.
Ohio hopes to be part of that group, said Medicaid Director Tracy Plouck. The state's goal is to be ready to help providers participate in the meaningful use program by the end of the fiscal year, which is June 30, 2011. If CMS sticks to its testing schedule, "we're pretty optimistic we'll be able to hit our milestones," she said.
Ohio has about 2.1 million Medicaid beneficiaries (out of 11.5 million residents), and has estimated that as many as 210 hospitals and 3,775 providers -- including doctors, dentists, nurse midwives and nurse practitioners -- can participate in the Medicaid meaningful use program.
Everyone involved recognizes the timeline is very aggressive, but there's reason for that.
Ruth Carr, health IT coordinator, state of Georgia
North Dakota, where about 65,000 residents (about 10% of its population) are covered by Medicaid, also is working on its draft health IT plan. The state will have to submit the draft to CMS before getting final approval for the plan, but the state feels comfortable it will be ready at the beginning of 2011 for Medicaid meaningful use.
North Dakota is planning to keep its interface with the NLR simple for the first year of the program: During that year, providers will need to prove only that they are buying or upgrading their EHR systems, said Nancy R. Willis, the state's Medicaid health IT coordinator. In addition, doctors will be able to use a website to verify that information.
After the first year of the program, a more complex system will be required, but North Dakota hopes to work with other organizations that will be collecting meaningful use criteria information -- such as the state's HIE or a nearby regional extension center -- so that Medicaid isn't overburdening doctors with reporting requirements, Willis said.
With all the new programs coming online for meaningful use, there's a race to get things done. "They all have directives to assist, but they all have different requirements, timelines and pots of money for getting there," Willis said. "And we're all working together -- but it all takes time."
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