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TennCare Electronic Health Record (EHR) Provider Incentive Payment Program

Understanding Attesting for Program Years (PY) 2020 and 2021

There is so much going on today that all we need is one more thing to confuse us. The intent of this article is to help you understand the EHR Incentive Program as we wind down. Just as a reminder, the last EHR Incentive Payment MUST go out the door no later than December 31, 2021 (other than adjustments and audits).

This article is for providers who have yet to receive 6 EHR Incentive Payments and are still eligible to attest. This means that you received at least one EHR Incentive Payment for any year through PY 2016.

Program Year 2020

  • Providers may submit PY 2020 attestations as soon as November 1, 2020 IF you are ready. CMS defines being “ready” as having completed your Security Risk Analysis (SRA) prior to submitting your attestation.
  • The deadline for submissions is March 31, 2021, 11:59 P.M., Central Time.
  • Your Patient Volume will come from a consecutive 90-day period in Calendar Year (CY) 2019.
  • Your Meaningful Use (MU) data, including eCQMs, will come from a consecutive 90-day period in CY 2020. This is a change from years past as CMS normally requires 365 days of eCQM data when attesting. (CMS would still prefer a year’s worth of data, but you do have the option.)

Program Year 2021

  • The submission period for PY 2021 begins July 1, 2021. CMS will allow you to attest prior to completing your annual SRA, but you must attest that you will complete and submit your SRA by December 31, 2021.
  • The deadline for submissions is September 30, 2021, 11:59 P.M., Central Time.
  •  If you attested for PY 2020, that attestation must be adjudicated before you can complete your PY 2021 attestation. That means we must review and either pass or deny your PY 2020 attestation prior to you completing your PY 2021 attestation. In fact, you will not be able to access your PY 2021 attestation until either payment is made or the attestation is denied.
  • Your Patient Volume will come from a consecutive 90-day period in CY 2020.
  • Your Meaningful Use (MU) data, including eCQMs, will come from a consecutive 90-day period in CY 2021. You may choose any 90 days starting with January 1, 2021 through July 31, 2021.
  • If you have not completed your annual SRA by the time you attest, you must complete your SRA by December 31, 2021. You are required to attest that you will complete the SRA by this date. States have the flexibility to require documentation that the SRA has been completed if conducted after the submission of the 2021 attestation.

We cannot emphasize enough that you understand the dates for attesting for PY 2021. You must attest in CY 2021. You cannot attest until your PY 2020 has been adjudicated, assuming you attested for PY 2020. The MU data collection period begins January 1, 2021 and ends July 31, 2021. If you choose to use May-June-July as your MU data collection period, you MUST still submit your attestation by September 30, 2021. If your SRA is not conducted pre-attestation, you must attest that one will be completed by December 31, 2021, and then you must do so. Failure to conduct the SRA will result in a finding if you are audited.

Should you have any questions:

The CMS web site also has a lot of information and FAQs. CMS has the overall responsibility for the EHR Provider Incentive Payment Program, and the CMS web site is very general in nature. You are more likely to find the answers you need here on TennCare’s web site to participate in the TennCare Medicaid EHR Incentive Program. If you want information about attesting under the MediCARE incentive program, you will need to go to CMS.

This table  is updated weekly showing the number of EPs and EHs who have been received EHR Incentive Payments since the inception of the TennCare EHR Provider Incentive Payment Program. As providers advance from AIU to meaningful use of their EHR systems, we expect both the number of providers and the amounts to rise. Haven’t enrolled yet? Go to the How to Register & Attest page to see how to begin.

On a monthly, and an as-needed basis, TennCare publishes an electronic newsletter to bring you the latest information about the EHR Provider Incentive Payment Program. We occasionally include information from CMS that we feel may be of interest to you.

We are now automatically enrolling all providers who are a part of the EHR Incentive Program. In case we miss you, or you are not yet enrolled, or just want to see what is being posted, you can subscribe by going to E-Blast newsletters. You can also go to E-Blast Newsletters to see past issues.

If you use a consultant to help with attesting: some providers use consultants to assist them in registering and attempting to qualify for the EHR Provider Incentive Program. This is an acceptable practice and TennCare does not have any objections to providers doing so. However, providers need to be aware that some consultants enter their own email address when registering the provider at the CMS R&A web site. As TennCare does all correspondence related to the EHR Incentive Program via email, all email is sent to the address entered when registering at CMS. If you are using a consultant who places their (the consultant’s) email address in your registration, you need to maintain close contact with the consultant as some attestation problems may require your intervention.