[EHR Incentive Programs] For Stage 1 and 2 meaningful use objectives of the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs that require submission of data to public health agencies, if multiple eligible professionals (EPs) are using the same certified EHR technology across several physical locations, can a single test or onboarding effort serve to meet the measures of these objectives?
The Stage 2 Final Rule (CMS-0044-F) changed the way shared Certified EHR Technologies are handled for testing, registration and onboarding of public health agencies for both Stage 1 and Stage 2. Previously, if multiple EPs are using the same certified EHR technology in different physical locations/settings (e.g., different practice locations), there must be a single test performed for each physical location/setting.
The intent of the public health objectives is to demonstrate that a provider has the full capability to use their certified EHR technology to successfully submit data to public health agencies in a live setting.
Under changes made in the Stage 2 Final Rule, providers within the same organization that use the same certified EHR technology and share a network for which their organization either has operational control of or license to use can conduct one test or one single effort to register and onboard that covers all providers in the organization. For example, if a large group practice of EPs with multiple physical locations uses the same EHR technology and those locations are connected using a network that the group has either operational control of or license to use, then a single test would cover all EPs in that group to meet this objective.
Please note that this provision only applies to meeting public health meaningful use objectives and does not supersede local, state and federal requirements stipulated by the public health registries themselves or other governing bodies such as local or state government.