FAQs Reported by CMS on EHR Incentive Programs

The Centers for Medicare & Medicaid (CMS) maintains a FAQ database on questions submitted for answers having to do with provider programs. Here are some of the latest entries to the database in the EHR Incentive Program category.

FAQ

Question: Am I permitted to count a patient in the numerator of the “record demographics” objective and measure if the preferred language I record for the patient is outside of the minimum required by the standard for Certified EHR Technology?

Answer: Yes, similar to the collection of race and ethnicity demographic data, we appreciate that providers may need to collect more precise information about preferred language to manage their patient population. If a patient’s preferred language is not included in the standard required for EHR technology certification, you may count that patient in the numerator of the measure as long as the preferred language is recorded as structured data, as required by the measure.

Question: Can an eligible professional (EP) or hospital charge patients a fee to have access to the certified EHR technology (CEHRT) solution that is used to meet the meaningful use objective of providing patients the ability to view online, download and transmit their health information?

Answer: We do not believe it would be appropriate for the EP or hospital to charge the patient a fee to access the Certified EHR Technology solution regardless of whether the solution is in the form of a provider-specific portal, an online personal health record, community portal or some other solution.

Question: When meeting the meaningful use measure for “secure messaging” in the EHR Incentive Programs, which requires that more than 5% of unique patients send a secure message using the electronic messaging function of CEHRT, is it required that the patient only use an interface that is certified or can any secure message received into the eligible professional’s CEHRT count for this measure?

Answer: As part of this objective, the eligible professional (EP) must make available to patients a secure messaging option certified to the 2014 edition certification criteria. However, this option is not the only way that a patient can send a secure message to an EP.

Question: When meeting the meaningful use measure for computerized provider order entry (CPOE), does an individual need to have the job title of medical assistant in order to use the CPOE function of certified EHR technology for the entry to count toward the measure, or can they have other titles as long as their job functions are those of medical assistants?

Answer FAQ #9058: If a staff member of the eligible provider is appropriately credentialed and performs similar assistive services as a medical assistant but carries a more specific title due to either specialization of their duties or to the specialty of the medical professional they assist, he or she can use the CPOE function of CEHRT and have it count towards the measure. This determination must be made by the eligible provider based on individual workflow and the duties performed by the staff member in question.

Question: For the Medicare and Medicaid EHR Incentive Programs, how should an eligible professional (EP), eligible hospital, or critical access hospital attest if the certified EHR vendor uses 2011 edition certified EHR technology for the first part of 2013 and 2014 edition certified EHR technology for the remainder of 2013?

Answer FAQ #9060: If an EP, eligible hospital or CAH switches from 2011 edition Certified EHR Technology to 2014 Edition Certified EHR Technology during the program year, the data collected for the selected menu objectives and quality measures should be combined from both of the EHR systems for attestation. The count of unique patients does not need to be reconciled when combining from the two EHR systems.

Question: How does a provider attest to a meaningful use objective (e.g., the “transitions of care,” “view/download patient data,” and public health objectives) where the provider electronically transmits data using technical capabilities provided by a HIE?

Answer FAQ #8908: Several meaningful use objectives require eligible professionals, eligible hospitals, and Critical Access Hospitals (CAH) to conduct electronic transmissions. In general, eligible professionals, eligible hospitals, and CAHs may use an HIE to meet a particular meaningful use objective if the HIE has been certified to support that objective. If an eligible professional, eligible hospital, or CAH uses an HIE to satisfy a particular meaningful use objective, the provider will need to include the HIE’s certification number, as a certified Electronic Health Records (EHR) Module, in their attestation.

Question: If an EP or hospital attesting to meaningful use in the EHR Incentive Program submits a successful test to the immunization registry in year 1 of Stage 1 and engages with the immunization registry in year 2, but does not achieve ongoing submission of data to the immunization registry during their reporting period in year 1 or year 2, should they attest to the measure or the exclusion?

Answer (FAQ8910): The Stage 1 MU measure requires the EP or hospital to perform at least one test of certified EHR technology’s capacity to submit electronic data to immunization registries, and follow-up submission if that test is successful. An EP or hospital that can demonstrate engagement with the immunization registry during year 2 would attest to meeting the measure even if that engagement was not in the form of another test. This engagement could be communication with the immunization registry showing that another test is not beneficial, work towards follow-up submission or an update showing that additional action by the provider towards follow-up submission is not beneficial for year 2. It is not acceptable to use the test from year 1 to meet the measure for year 2. The provider needs to show evidence of action taken during year 2 that demonstrates both that another test is not beneficial in moving towards follow-up submission and that follow-up submission is not possible in year 2. This principle applies to all of the public health objectives.

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