On February 29, 2016, the Centers for Medicare and Medicaid Services (CMS) issued a State Medicaid Directors Letter (SMDL) that expands the scope of expenditures eligible for the 90 percent federal match for activities to promote the use of a health information exchange (HIE) and the adoption of certified electronic health record (EHR) technology by Medicaid providers.
Specifically, this updated guidance permits States to claim the enhanced match for expenditures that promote coordination of care between entities eligible for EHR incentive payments and other Medicaid providers who may not necessarily qualify for such payments. This SMDL supersedes earlier guidance that did not permit the enhanced match for these activities.
Expansion of Enhanced Match for Coordination Activities Among Non-Eligible Professionals
In previous guidance, CMS took the position that States could only receive an enhanced match for activities that promote interconnectivity and coordination of care between eligible providers. CMS now reverses course and provides that costs for activities that promote use of EHR by others (i.e., non-eligible providers) may be matched at 90 percent if the State expenditures on these activities help eligible providers meet meaningful use objectives. Funding for these activities is available as of the date of the letter (February 29, 2016) and will not be available retroactively.
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CMS explains that the enhanced match may be available for following types of state costs:
On-boarding Medicaid providers to Health Information Exchanges
States may claim the enhanced match for activities to on-board Medicaid providers onto a HIE or any interoperable system that connects eligible providers to other Medicaid providers. CMS clarifies that the enhanced match is available for implementation only, not continued costs of keeping providers connected to the HIE. The enhanced match is also available for costs for supporting the initial on-boarding of pharmacies, clinical laboratories, and public health providers to HIEs or other interoperable systems. CMS reiterates that on-boarding must support eligible providers’ efforts to meet meaningful use objectives.
States may claim the enhanced match for costs related to the design, development, and implementation of infrastructure for several HIE components and interoperable systems that connect eligible providers to other Medicaid providers, when this infrastructure helps eligible providers demonstrate Meaningful Use. CMS reiterates, however, that there is no enhanced match for ongoing and maintenance costs after this technology is established and functional.
CMS provides the following, non-exhaustive, list of the types of state costs for the design, development, and implementation of HIE infrastructure for which the 90 percent match may be claimed.
Date: April 1, 2016