Critical Access Hospital (CAH) EHR Incentive Required Documentation

Pursuant to §4102(a)(2) of the HITECH ACT, Critical Access Hospitals (CAHs) may be eligible for a payment incentive for the purchase of certified electronic health record technology. This reimbursement may include the cost of the software itself as well as the cost of any computer hardware or software "necessary to administer" the certified health record technology.

There have been many questions asked about how this affects CAHs, what they need to submit for reimbursement, etc. These questions have been listed below, along with the steps for CAH reimbursement, and a spreadsheet template that shows what type of listing we will need for the initial review of documentation. Please note that any items listed on the spreadsheet may be selected for a detailed review. If we select a particular item for review, we will request detailed documentation such as invoices, purchase orders, depreciation schedules, etc. that we can vouch the summary documentation to.

  1. What benefit does a CAH get from this program above and beyond normal cost reimbursement? Instead of the normal 101% of Medicare's share of the cost (depreciated over several years) that a CAH would normally receive as reimbursement, they will receive 120% of Medicare's share (up to 100% of the asset's purchase price.) Furthermore, instead of this being depreciated over several years, it will be expensed in the first year. Furthermore, the Medicare share calculation under the EHR incentive is more generous, as charity care charges will tend to increase Medicare Share above the normal "Medicare day to total day" Medicare share calculation.
  2. What amount is allowed for reimbursement? Only the purchase price itself (less any accumulated depreciation for assets purchased prior to the start of this incentive) is allowed for this incentive. Although there may be other items that are commonly included in the historical cost basis of such an asset for depreciation purposes, these additional items will not be allowed for this incentive payment purpose. Instead, such costs must be capitalized and depreciated, as they normally would have been.
  3. When should the CAH submit their documentation? Shortly after they register and attest as a meaningful user. It is not appropriate for a CAH to send in the information any earlier than that, as we cannot continue on and do anything for the review until we receive verification from the National Level Repository that the CAH has attested.
  4. What documentation does a CAH need to send in for the initial payment? Generally, we will need a spreadsheet listing out all of the assets that you are including for reimbursement under this incentive program. Remember that this can only include the purchase cost of the certified EHR technology as well as the purchase price of any computer hardware of software that is necessary to administer the certified EHR technology. See the end of this article for a link to a sample spreadsheet.

Note that the very first entry(ies) on the top of the spreadsheet should be the certified EHR assets themselves. We will need the basic information about the asset (purchase date, price, name, description, etc. but we will also need the certification #, version # and any other details that you can get from the attestation website or CMS's certified technology listing website. If we are unable to tie at least one certified asset to the CMS listing, this immediately disallows the entire listing, as everything has to be linked to one or more certified EHR assets in order for any incentive reimbursement to take place.

Once you have included the necessary information about the certified EHR you can then begin to list information about the other computer hardware or software assets that were "necessary to administer" the certified EHR. We will need the basic information about the asset itself (i.e. purchase date, price, accumulated depreciation, etc.) but we will also need information about what the asset is, what it does, and why it is "necessary to administer" the certified EHR. Furthermore, we will need information about approximately what percentage of the asset's use is related to administering/supporting the certified EHR versus some other use it may have. Only the portion related to certified EHR purposes would be allowable for this incentive.

For more detailed FAQS, see the CMS EHR Incentive website at the following link: http://www.cms.gov/EHRIncentivePrograms/(external link)

Please note that the CAH Incentive Payment process has a few stages.

Stage 1: The initial information is submitted by the provider after that provider has registered and attested as a meaningful user.

Stage 2: The FI/MAC will respond within 10 days as to whether any additional information is needed for the initial payment

Stage 3: Once the FI/MAC receives the requested information, they will then complete the initial review within 30 days. The information on the allowable cost, along with Medicare share data retrieved from the latest cost report, will be entered into the Claims Processing System (FISS) where the National Level Repository (NLR) will gather the data and process the payment.

Stage 4: Although an initial payment was made when the data was first submitted, these payments will be reconciled during the desk review/audit of the cost report for the period in which the incentive payment(s) were claims. At that time, it is likely that supporting documentation for the listing (e.g. invoices, depreciation schedules, etc.) will be requested for detailed auditing. Although generally only a sample will be selected for review, the auditor reserves the right to request detailed information for any and all items on the listing. Note that the Medicare share data will also be recalculated if any of the components themselves have changed during the final settlement of the cost report.

Stage 5: If needed, a payment adjustment for the incentive payment will be processed based on the review of the final cost report and/or underlying data.

Sample Critical Access Hospital (CAH) Electronic Health Record (EHR) Incentive Payment ListingExcel File to Submit


Please submit your CAH HITECH documentation via mail or e-mail to the contact below:

Fed Ex/Overnight

WPS Medicare
ATTN: Chris Severson
Medicare Audit Advisement
3333 Farnam Street, Suite 700
Omaha, NE 68131

USPS

WPS Medicare
ATTN: Chris Severson
Medicare Audit Advisement
PO Box 8310
Omaha, NE 68108-0310

E-mail

chris.severson@wpsic.com

Page Last Updated: Thursday, 22-Dec-2011 11:54:28 CST