Attestation & Payment Years

IMPORTANT DEADLINE UPDATE: 2016 IS THE LAST YEAR PROVIDERS CAN ENROLL AND PARTICIPATE IN THE EHR PROVIDER INCENTIVE PROGRAM

2016 is the last year in which providers can enroll and begin attesting in the TennCare Medicaid EHR Provider Incentive Payment Program. After 2016, the only providers who are “new” to Tennessee and will be able to attest are those who have previously attested in the Medicaid EHR Incentive Program of another state.

Eligible Professionals (EPs)

Payment Year 1:​
  • EPs must show & document Adoption, Implementation, or Upgrading (AIU) to a certified EHR system. Program Year 2016 is the last year for which AIU attestations may be submitted.
  • Patient Volume (PV) data (both Medicaid and Total) are from a consecutive 90-day period in the previous calendar year. CMS requirements are that EPs have a PV equal to or exceeding 30% paid Medicaid encounters for the qualifying period. (Pediatricians may qualify for a reduced payment if their paid Medicaid encounter PV equals to or exceeds 20%; however, if a pediatrician’s Medicaid PV equals or exceeds 30%, then the pediatrician is eligible for the full EHR Incentive payment. Our evaluation is based on the data submitted. If a pediatrician’s PV equals or exceeds 30%, you must show this through your number of Medicaid encounters/Total encounters.) For example, an EP attesting for the first time in 2016 will use PV data from 2015; in 2017 use 2016 data, etc.
  • The first year EHR incentive payment for EPs who meet the PV requirement of 30% or greater is $21, 250. The EHR Incentive payment for Pediatricians who meet the PV requirement of 20% - 29% is $14,167. These payment amounts are set by statute, and there are no partial payments made.
Payment Year 2:
  • When attesting for Meaningful Use (MU) for the first time, EPs must meet the MU criteria using a consecutive 90-day period in the program year being submitted. For example, to attest to MU in 2015, EPs must use a 90-day reporting period in 2015. If an EP begins the 90-day reporting period on January 1, the earliest date the provider can attest to meeting MU criteria would be in early April.  Attesting to MU in the second and subsequent years requires that providers submit 365 days of MU data. For example, a second year MU attestation for Program Year 2016 requires 365 days of MU data, meaning that providers will not be able to attest until January of 2017.
  • Note: The MU period for attestations is subject to CMS rule. Should a change occur, both CMS and the Bureau of TennCare will notify providers of any change.
  • Patient Volume (PV) data (both Medicaid and Total) must be from a consecutive 90-day reporting period in the previous calendar year. To attest to MU in 2016, the PV data must come from a 90-day reporting period in 2015.
  • More information about MU criteria can be found on the Meaningful Use page.  
  • The EP EHR Incentive Payment amount for Payment Years 2 - 6 is $8,500 (per year) for EPs (including pediatricians) meeting the 30% or greater PV requirements, and $5,667 for Pediatricians who have PVs in the 20% - 29% range. These payment amounts are set by statute, and there are no partial payments made.
Payment Years 3 - 6:

EPs must successfully attest to MU criteria for the full calendar year. EPs cannot attest to MU until the calendar year is complete; for example, to earn a Program Year 3 incentive payment for 2016, an EP would not be able to attest until 2017, once the 2016 data can be calculated and reported. The Attestation Program Year would be 2016.

Note: The MU data period for attestations is subject to CMS rule. Should a change occur, both CMS and the Bureau of TennCare will notify providers of any change.

Patient Volume (PV) data (both Medicaid and Total) must be from a consecutive 90-day period in the calendar year preceding the MU reporting period. If the MU reporting period were the full calendar year of 2016, then PV data would be a consecutive 90-day period in 2015.

Total EHR Incentive Payments

EPs who have Medicaid encounters of 30% or greater during the six-year EHR Incentive Period will earn a total of $63,750.

Pediatricians having Medicaid encounters in the 20% - 29% range during each year of the six-year EHR Incentive period will earn a total of $42,000.  Pediatricians whose Medicaid patient volume equal or exceed 30% are eligible for the full EHR Incentive Payment. However, your Medicaid Encounters/Total Encounters must equal or exceed 30%. Our determination of the incentive payment for which you are eligible is subject to the information you submit.

These payment amounts are set by statute, and there are no partial payments made.

Eligible Hospitals (EHs)​ TennCare is making the EH EHR Incentive Program Payments over a 3-year period. The EH's EHR Incentive Payment is 50% in the first year, 30% in the second year, and 20% in the third year.  Effective December 15, 2015, CMS changed the EH attestation reporting period from a federal fiscal year to the calendar year. However, the hospital’s patient volume requirement (10%) remains based on the fiscal year. NOTE: Children’s hospitals do not have a minimum patient volume requirement.

Note: CMS has changed the MU attestation period (the number of days you need for MU data) several times since the inception of the program. Although it is well publicized, it you have a question as to whether 90 days of MU data is required, or 365 days, send an email to EHRMeaningfuluse.TennCare@tn.gov and ask.

  • ​For EHs attesting under the TennCare Medicaid EHR Incentive Program for MU the first time (attested for AIU in year 1), the MU reporting requirement period is for a consecutive 90-day period in the Program Year for which the EH is attesting.
  • If the EH attested for MU with TennCare Medicaid in the first year, the MU reporting period for the second year is 12 months in the Program Year for which the EH is attesting.
  • Patient Volume (PV) data (both Medicaid and Total) must be from a consecutive 90-day period in the previous fiscal year to the Program Year for which the EH is attesting. PV must equal or exceed 10% for acute care hospitals and CAHs.
  • Children's hospitals do not have to meet a PV requirement.
Payment Year 1:​
  • EHs must show & document Adoption, Implementation, or Upgrading (AIU) to a certified EHR system. (Medicaid attestations only; Medicare always requires Meaningful Use [MU] data.) Program Year 2016 is the last year for which AIU attestations will be accepted.
  • Patient Volume (PV) data (both Medicaid and Total) is calculated from a consecutive 90-day period in the previous calendar year and must equal or exceed 10% for acute care hospitals and Critical Access Hospitals (CAHs). Children's hospitals do not have to meet a PV requirement.
  • Providers must begin registration and attestation no later than 2016 In order to receive all incentive payments through 2021. (42 CFR § 495.310(f)(5) – No hospital may begin receiving incentive payments for any year after FY 2016, and after FY 2016, a hospital may not receive an incentive payment unless it received an incentive payment in the prior fiscal year. [That is, EHs will not be allowed to skip a year after 2016])
  • The EH's EHR Incentive Payment is based on information the EH submits with the first attestation. 
Payment Year 2:

Note: Per CMS, if an EH attests with both Medicare and Medicaid in the first year, that EH has used its 90-day MU attestation period. Attestation for the second payment year requires a full year of MU data.

  • For EHs attesting under the TennCare Medicaid EHR Incentive Program for MU the first time (attested for AIU in year 1), the MU reporting requirement period is for a consecutive 90-day period in the Program Year for which the EH is attesting.
  • If the EH attested for MU with TennCare Medicaid in the first year, the MU reporting period for the second year is 12 months in the Program Year for which the EH is attesting.
  • Patient Volume (PV) data (both Medicaid and Total) must be from a consecutive 90-day period in the previous fiscal year to the Program Year for which the EH is attesting. PV must equal or exceed 10% for acute care hospitals and CAHs.
  • Children's hospitals do not have to meet a PV requirement.

The rule changes that became effective December 15, 2015, made several changes to the MU reporting period for EHs. If you have any questions, please email EHRMeaningfuluse.TennCare@tn.gov.

Go to the MU Overview page for more information about MU.

Payment Year 3:
  • The MU data reporting requirement for Payment Year 3 is 12 months in the Program Year for which the EH is attesting. Note: The MU period for attestations is subject to CMS rule. Should a change occur, both CMS and the Bureau of TennCare will notify providers of any change.
  • Patient Volume (PV) data (both Medicaid and Total) must be from a consecutive 90-day period in the previous fiscal year to the Program Year for which the EH is attesting. PV must equal or exceed 10% for acute care hospitals and CAHs.
  • Children's hospitals do not have to meet a PV requirement.
  • Prior to making the third year EHR Incentive Payment, TennCare will audit the EH’s previous incentive payments to determine if the EH was overpaid or underpaid the first two years. The amount of the third year EHR Incentive Payment will be adjusted as necessary.