How to Attest to SUD PIP Milestone Achievements

How to Attest to SUD PIP Milestone Achievements

by Joseph D'Allegro, February 14, 2020

The Promoting Interoperability Program (PIP) run by the Centers for Medicare & Medicaid Services (CMS) calls on Substance Use Disorder (SUD) providers to attest to their achievement of specific milestones. For SUD providers in the Garden State, that means using the New Jersey Medicaid Management Information System’s (NJMMIS) provider portal.

The provider portal is run by the state’s Department of Human Services (DHS) and is simple to use. It merely requires providers to log in, click on the EHR Incentive Program button on the left, then enter the SUD Promoting Interoperability Program section of the site to register and add their National Provider ID (NPI) information. They can then begin the attestation process and upload supporting documents.

Though the NJMMIS provider portal is easy to use, some users have run into issues with documentation. For instance, attesting to Milestone 1 (explained below) requires both a fully-executed Participation Agreement and a signed EHR vendor contract. In addition, SUD providers must show that their EHR vendors have earned 2015 Edition certification from the Office of the National Coordinator for Health Information Technology (ONC). 

Any providers having trouble with NJMMIS’ portal should call DXC Technology Provider Services at (800) 776-6334 (option 7) for assistance. Please be sure to specify that you are calling in reference to the SUD PIP Program in order to assist you accordingly.

Background

The SUD PIP program is meant to enhance coordination among substance use disorder providers and the rest of the healthcare system by increasing your access to electronic health records (EHR). The state’s DHS wants an increased use of EHRs between SUD providers, other clinics, and hospitals which will ultimately allow clinicians to access the full scope of information when patients come in for care.

SUD PIP practices that meet the CMS milestone by connecting to the NJHIN, can sign up to receive an alert any time one of their patients is admitted, discharged or transferred from or to any of the 71 acute care hospitals in NJ. This enables pro-active coordination of care and can provide better support for patients with multiple or chronic conditions. It can also help identify patients who are frequent or heavy users of New Jersey hospitals facilities to provide appropriate support from non-acute facilities and providers.

Eligibility Requirements 

Non-profits, for-profits, and governmental entities are eligible to join the PIP program, but they must be Medicaid providers with adjudicated claims from Medicaid. Providers must also be licensed by the Department of Health’s Office of Licensing (OOL) to provide SUD treatment prior to the start of services, and receive funding from the DHS’ Division of Mental Health and Addiction Services (DMHAS) to provide SUD treatment services, either through cost-based contract or fee-for-service. Finally, the last requirement states that the practice has to have had at least 50 SUD admissions during calendar year 2018 documented in NJSAMS.

Providers meeting the above criteria can then begin the first step to achieving milestone 1 which is to review, complete and sign the SUD PIP Participation Agreement (PA) and Business Association Agreement (BAA). 

In addition to the signed PA and BAA, please see the documentation requirements in Attachment 3 of the PA, specifically a copy of your W-9, a copy of your business registration certificate, and evidence of filing form AA302 (Employee Information Report). Please also submit a copy of your organization’s Department of Health’s Office of Licensing (OOL) number or certificate along with your submission.

Once the state has reviewed your documentation and has deemed your organization eligible to participate, you may then submit a Participation Agreement along with data through the NJMMIS provider portal will receive incentive payments, as outlined below.

Milestones

SUD PIP milestones are outlined below, along with the resulting payment providers receive for meeting them.

  1. Participation Agreement/ EHR Vendor Contract Agreement(provider signs an EHR vendor contract, joining the program) – $5,000
  2. NEW EHR 2015 ONC Certified EHR Implementation Go-live – $20,000 OR Upgrade to existing EHR that is 2015 ONC Certified Go-live  – $7,500
  3. The SUD joins the New Jersey Health Information Network (NJHIN/HIE Connectivity) – $7,500
  4. SUD joins the N.J. Prescription Monitoring Program (PMP Connectivity or another quality metric) – $5000
  5. SUD joins the New Jersey Substance Abuse Monitoring System (NJSAMS Connectivity or another quality metric) – $5,000

If your practice is not already involved in the SUD PIP program and meets the eligibility requirements outlined above, please contact the NJII team responsible for onboarding providers to the program at sudpip@njii.com to learn more and get started.