Provider Resources

Access FAQs and resources that address interoperability, HIE connectivity, and telehealth

HCBS Promoting Interoperability

The HCBS PI Program rewards HCBS providers for meeting milestones to adopt and implement certified electronic health record (EHR) technology and connect to the DC HIE.

HCBS PI is an incentive program.

Frequently Asked Questions

What provider organizations are eligible to receive HCBS PI Program incentive payments from DHCF?

DHCF has established the following eligibility criteria to participate in the HCBS PI Program: 1) A non-profit or for-profit entity or governmental entity; 2) A Medicaid provider organization that has adjudicated claims within FY21-FY23 from Department of Health Care Finance (DHCF) to provide services either through contract or fee-for-service; and 3) Licensed, as applicable, by an affiliated government agency:

Department of Behavioral Health (DBH):
- Mental Health Rehabilitation Services (MHRS);
- Adult Substance Abuse Rehabilitation Services (ASARS); and
- Other certified Rehabilitation Services providers
Department of Health Care Finance (DHCF):
- Home Health Agencies (HHA);
- Assisted Living Facilities (ALF); and
- Certified Medical Assistant (CMA) providers
- Adult Day Health Programs (ADHP) enrolled by DHCF to deliver 1915(c) or 1915(i) services or supports
Department of Disability Services (DDS):
- Providers delivering 1915(c) services or supports authorized under the People with Intellectual and Developmental Disabilities HCBS Waiver Program (IDD Waiver) and the Individual and Family Supports HCBS Waiver Program (IFS Waiver)
Department of Human Services (DHS):
- Housing Support Services (HHS)

If a provider organization purchased or upgraded its health IT before the start of the HCBS PI Program, is it eligible to participate?

Yes; if the health IT purchase or upgrade was made on or after January 1, 2022, the provider organization is eligible to participate in the HCBS PI Program.

If a provider organization sent data to the DC HIE prior to the start of the HCBS PI Program, is it eligible to receive Milestones 5 and/or 6?

Yes; if the provider organization began sending data to the DC HIE on or after January 1, 2022, the provider organization is eligible to receive Milestone 5 and/or 6 incentive payments through the HCBS PI Program.

How is a provider organization’s Track determined?

Track is determined based on an assessment performed:

Track 1 is appropriate for HCBS provider organizations that have not yet adopted certified EHR technology in their practice
Track 2 is appropriate for HCBS provider organizations that need to upgrade to certified EHR technology in their practice
Track 3 is appropriate for HCBS provider organizations that would like to optimize their existing (certified or non-certified) EHR or case management system

Are provider organizations that practice outside the District of Columbia eligible to receive HCBS PI incentives?

Eligibility is contingent upon having adjudicated claims with DHCF for FY21 – FY23 and being licensed through the DC Department of Behavioral Health, Department of Health Care Finance, Department of Disability Services, or the Department of Human Services. Provider organizations must practice within the District of Columbia to participate in the HCBS PI program.

Are HCBS PI Program incentives received as separate payments from DHCF?

HCBS PI Program incentives payments are bundled with other payments from DHCF; contact your eHealthDC TA to provide a tracking number.

HCBS PI Attestation Checklists

Milestone 7
Webinars

Milestone 8
Training Sessions

HIE Connectivity

The DC HIE is a system of HIE entities that meet common privacy and security standards to support the secure electronic exchange of health information. eHealthDC helps providers connect to DC HIE so they can share patient data right from their EHR.

DC HIE Entities

CRISP DC is the designated health information exchange (HIE) serving the District of Columbia

Services Provided to the District

CSS Event Notification Delivery (CEND)
PopHealth Analytics Reporting
Consent to Share SUD Data
Health Related Social Needs Screening & Referrals
Advance Care Planning Application
Provider Directory Tool

Capital Partners in Care Health Information Exchange (CPC-HIE) services provided to the District

Services Provided to the District

Safety-net provider network that includes Federally Qualified Health Centers
eClinicalWorks EHR information
eClinicalWorks Electronic Health eXchange (eEHX) hub
Participating providers share patient encounter and treatment information
Single-sign-on (SSO) connection to CRISP

Telehealth

The HCBS Telehealth Technical Assistance (TA) program builds on the efforts to expand the use of certified EHR technology, extends telehealth investments, and encourages the use of remote patient monitoring devices.

HCBS Telehealth TA is not an incentive program.

Frequently Asked Questions

Is my HCBS organization eligible to participate in the HCBS Telehealth Technical Assistance Program?

HCBS Telehealth Technical Assistance Provider Eligibility Criteria:

A non-profit or for-profit entity or governmental entity
A Medicaid provider organization that has adjudicated claims within FY21-FY23 from DHCF to provide services through contract or fee-for-services either through contract or fee-for-service
Licensed, as applicable, by an affiliated government agency:

Department of Behavior Health (DBH)
Department of Health Care Finance (DHCF)
Department of Disability Services (DDS)
Department of Human Services (DHS)

Are all HCBS Provider Types eligible to deliver telehealth services?

Per the DC Department of Healthcare Finance, the following HCBS providers are eligible:

Mental Health Rehabilitation Service Providers (MHRS)
Adult Substance Abuse Rehabilitation Services Providers (ASARS)
Adolescent Substant Abuse Treatment Expansion Program Provider (ASTEP)

Does my organization need a HIPAA-compliant telemedicine platform to render telehealth services?

Yes. On April 11, 2023, the Office for Civil Rights (OCR) announced that effective May 12, 2023, all eligible telehealth participating healthcare providers will have a 90-day transition period to comply with the HIPAA Rules with respect to utilizing a HIPAA-compliant telehealth platform to render telehealth services in a private and secure manner. The transition period will expire on August 9, 2023.

Is a Business Associates Agreement (BAA) required between my organization and the telehealth services provider?

Providers should understand that using a non-HIPAA compliant third-party application without an established business associate agreement introduces unnecessary privacy and security risks. In addition, use of these tools does not guarantee a provider from other legal action concerning the failure to protect a beneficiary’s Protected Health Information (PHI).

Is obtaining consent for telehealth required at every visit?

Yes. A provider shall document the beneficiary’s consent to receive telemedicine services at every visit, even if the patient has previously provided consent.

Written consent includes any method that documents in writing the beneficiary’s

agreement to receive the service via telemedicine, including but not limited to an e-mail, text message, or signed PDF. If verbal consent is obtained, a detailed service note that describes the beneficiary’s verbal consent is required.

Can the telehealth visit be audio-only?

Yes. HIPAA covered entities can use remote communication technologies to provide telehealth services, including audio-only services, in compliance with the HIPAA Privacy Rule.

Is Remote Patient Monitoring (RPM) telehealth?

Yes. RPM is a form of telehealth; however, the DC Medicaid program currently does not reimburse for remote patient monitoring services.

Is a compliance plan needed for telehealth?

All telemedicine providers shall develop a confidentiality compliance plan in accordance with the HIPAA Act of 1996. The compliance plan should incorporate appropriate administrative, physical, and technical safeguards around data encryption to protect the privacy of telemedicine participants and ensure compliance with the HIPAA and the HITECH Act of 2009.