CMS answers more meaningful use FAQs
The Centers for Medicare & Medicaid Services (CMS) has answered several additional frequently asked questions (FAQs) regarding meaningful use. Some of the new FAQs and answers include:
What information must an eligible professional (EP) provide in order to meet the measure of the meaningful use objective for "provide patients with an electronic copy of their health information" under the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs?
The final rule limited the information that must be provided electronically to that information that exists electronically in or is accessible from the certified EHR technology and is maintained by or on behalf of the eligible professional (EP), eligible hospital or critical access hospital (CAH).
All providers are encouraged to meet a patient’s request for information with all of the information that the patient requests and meets the description above. However, if the provider’s certified EHR technology cannot provide all patient-requested information within the three-business-day timeline, a minimum level of information is defined in the certification process. All EHR technology is certified for the purposes of this program to provide a problem list, diagnostic test results, medication list and medication allergy list.
An EP, eligible hospital or CAH that provides these four elements within three business days of the patient request meets the measure associated with this objective. We encourage all providers to continue to work with patients to provide information patients may request above and beyond these four elements.
When a patient is only seen by a member of the EP’s clinical staff during the EHR reporting period and not by the EP, do those patients count in the EP’s denominator?
EPs can include or not include those patients in their denominator at their discretion as long as:
In cases where a member of the EP’s clinical staff is eligible for the Medicaid EHR incentive in hir or her own right—nurse practitioners (NPs) and certain physician assistants (PAs)—patients seen by NPs or PAs under the EP's supervision can be counted by both the NP or PA and the supervising EP as long as the policy is consistent for the entire EHR reporting period.
How does an EP determine whether a patient has been “seen by the EP” in cases where the service rendered does not result in an actual interaction between the patient and the EP, but minimal consultative services such as just reading an EKG? Is a patient seen via telemedicine included in the denominator for measures that include patients “seen by the EP?”
All cases where the EP and the patient have an actual physical encounter with the patient in which they render any service to the patient should be included in the denominator as “seen by the EP.” Also a patient seen through telemedicine would still count as a patient “seen by the EP.”
However, in cases where the EP and the patient do not have an actual physical or telemedicine encounter, but the EP renders a minimal consultative service for the patient (such as reading an EKG), the EP may choose whether to include the patient in the denominator as “seen by the EP,” provided the choice is consistent for the entire EHR reporting period and for all relevant meaningful use measures.
EPs who never have a physical or telemedicine interaction with patients must adopt a policy that classifies as least some of the services they render for patients as “seen by the EP” and this policy must be consistent for the entire EHR reporting period and across meaningful use measures that involve patients “seen by the EP’’—otherwise, these EPs would not be able to satisfy meaningful use, as they would have denominators of zero for some measures.
Click here to see the updated list of CMS FAQs and answers.
What information must an eligible professional (EP) provide in order to meet the measure of the meaningful use objective for "provide patients with an electronic copy of their health information" under the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs?
The final rule limited the information that must be provided electronically to that information that exists electronically in or is accessible from the certified EHR technology and is maintained by or on behalf of the eligible professional (EP), eligible hospital or critical access hospital (CAH).
All providers are encouraged to meet a patient’s request for information with all of the information that the patient requests and meets the description above. However, if the provider’s certified EHR technology cannot provide all patient-requested information within the three-business-day timeline, a minimum level of information is defined in the certification process. All EHR technology is certified for the purposes of this program to provide a problem list, diagnostic test results, medication list and medication allergy list.
An EP, eligible hospital or CAH that provides these four elements within three business days of the patient request meets the measure associated with this objective. We encourage all providers to continue to work with patients to provide information patients may request above and beyond these four elements.
When a patient is only seen by a member of the EP’s clinical staff during the EHR reporting period and not by the EP, do those patients count in the EP’s denominator?
EPs can include or not include those patients in their denominator at their discretion as long as:
- The decision applies universally to all patients for the entire EHR reporting period; and
- The EP is consistent across meaningful use measures.
In cases where a member of the EP’s clinical staff is eligible for the Medicaid EHR incentive in hir or her own right—nurse practitioners (NPs) and certain physician assistants (PAs)—patients seen by NPs or PAs under the EP's supervision can be counted by both the NP or PA and the supervising EP as long as the policy is consistent for the entire EHR reporting period.
How does an EP determine whether a patient has been “seen by the EP” in cases where the service rendered does not result in an actual interaction between the patient and the EP, but minimal consultative services such as just reading an EKG? Is a patient seen via telemedicine included in the denominator for measures that include patients “seen by the EP?”
All cases where the EP and the patient have an actual physical encounter with the patient in which they render any service to the patient should be included in the denominator as “seen by the EP.” Also a patient seen through telemedicine would still count as a patient “seen by the EP.”
However, in cases where the EP and the patient do not have an actual physical or telemedicine encounter, but the EP renders a minimal consultative service for the patient (such as reading an EKG), the EP may choose whether to include the patient in the denominator as “seen by the EP,” provided the choice is consistent for the entire EHR reporting period and for all relevant meaningful use measures.
EPs who never have a physical or telemedicine interaction with patients must adopt a policy that classifies as least some of the services they render for patients as “seen by the EP” and this policy must be consistent for the entire EHR reporting period and across meaningful use measures that involve patients “seen by the EP’’—otherwise, these EPs would not be able to satisfy meaningful use, as they would have denominators of zero for some measures.
Click here to see the updated list of CMS FAQs and answers.