When eligible professionals work at more than one clinical site of practice, are they required to use data ...
- CMS considers these two separate, but related issues. Meaningful use: Any eligib... (more)
- CMS considers these two separate, but related issues. Meaningful use: Any eligible professional demonstrating meaningful use must have at least 50% of their patient encounters during the EHR reporting period at a practice/location or practices/locations equipped with certified EHR technology capable of meeting all of the meaningful use objectives. Therefore, States should collect information on meaningful users' practice locations in order to validate this requirement in an audit. Patient volume ;Eligible professionals may choose one (or more) clinical sites of practice in order to calculate their patient volume. This calculation does not need to be across all of an eligible professional's sites of practice. However, at least one of the locations where the eligible professional is adopting or meaningfully using certified EHR technology should be included in the patient volume. In other words, if an eligible professional practices in two locations, one with certified EHR technology and one without, the eligible professional should include the patient volume at least at the site that includes the certified EHR technology. When making an individual patient volume calculation (i.e., not using the group/clinic proxy option), a professional may calculate across all practice sites, or just at the one site. For more information on applying the group/clinic proxy option, see FAQ #10362 or http://questions.cms.hhs.gov/app/answers/detail/a_id/10362/kw/group%20practice/session/For more information about the Medicare and Medicaid EHR Incentive Program, please visit http://www.cms.gov/EHRIncentivePrograms
How is hospital-based status determined for eligible professionals in the Medicaid Electronic Health Record...
- A hospital-based eligible professional (EP) is defined as an... (more)
- A hospital-based eligible professional (EP) is defined as an EP who furnishes 90% or more of their covered professional services in either the inpatient (Place of Service 21) or emergency department (Place of Service 23) of a hospital. Covered professional services are physician fee schedule (PFS) services paid under Section 1848 of the Social Security Act. CMS uses PFS data from the Federal fiscal year immediately preceding the calendar year for which the EHR incentive payment is made (that is, the "payment year") to determine what percentage of covered professional services occurred in either the inpatient (Place of Service 21) or emergency department (Place of Service 23) of a hospital. The percentage determination is made based on total number of Medicare allowed services for which the EP was reimbursed, with each unit of a CPT billing code counting as a single service. States will use claims and/or encounter data (or equivalent data sources at the State's option) to make this determination for Medicaid. States may use data from either the prior fiscal or calendar year. For the Medicaid EHR Incentive Program, EPs should contact their states for more information. For more information about the Medicaid EHR Incentive Program, please visit http://www.cms.gov/EHRIncentivePrograms
While the denominator for measures used to calculate meaningful use in the Medicare and Medicaid Electronic...
- ... (more)
- The criteria for a numerator is not constrained to the EHR reporting period unless expressly stated in the numerator statement for a given meaningful use measure. The numerator for the following meaningful use measures should include only actions that take place within the EHR reporting period: Preventive Care (Patient Reminders) and Secure Electronic Messaging.For all other meaningful use measures, the actions may reasonably fall outside the EHR reporting period timeframe but must take place no earlier than the start of the reporting year and no later than the date of attestation in order for the patients to be counted in the numerator, unless a longer look-back period is specifically indicated for the objectives or measure. For program year 2015 and subsequent years, the requirements have been defined in the final rule (80 FR 62792). For more information specific to the Security Risk Assessment in 2015 and subsequent years, see https://questions.cms.gov/faq.php?isDept=0&search=8231&searchType=faqId&submitSearch=1&id=5005 (2017 OPPS Rule) FAQ #13649 Created on 4/26/2013
Updated on 6/23/2014
Updated on 9/24/2015
Updated on 12/11/2015
Updated on 12/14/2015
If an eligible professional (EP) in the Medicaid EHR Incentive Program wants to leverage a clinic or group ...
- EPs may use a clinic or group practice's patient volume as a... (more)
- EPs may use a clinic or group practice's patient volume as a proxy for their own under three conditions: (1) The clinic or group practice's patient volume is appropriate as a patient volume methodology calculation for the EP (for example, if an EP only sees Medicare, commercial, or self-pay patients, this is not an appropriate calculation);
(2) there is an auditable data source to support the clinic's patient volume determination; and (3) so long as the practice and EPs decide to use one methodology in each year (in other words, clinics could not have some of the EPs using their individual patient volume for patients seen at the clinic, while others use the clinic-level data). The clinic or practice must use the entire practice's patient volume and not limit it in any way. EPs may attest to patient volume under the individual calculation or the group/clinic proxy in any participation year. Furthermore, if the EP works in both the clinic and outside the clinic (or with and outside a group practice), then the clinic/practice level determination includes only those encounters associated with the clinic/practice. In order to provide examples of this answer, please refer to Clinics A and B, and assume that these clinics are legally separate entities. If Clinic A uses the clinic's patient volume as a proxy for all EPs practicing in Clinic A, this would not preclude the part-time EP from using the patient volume associated with Clinic B and claiming the incentive for the work performed in Clinic B. In other words, such an EP would not be required to use the patient volume of Clinic A simply because Clinic A chose to invoke the option to use the proxy patient volume. However, such EP's Clinic A patient encounters are still counted in Clinic A's overall patient volume calculation. In addition, the EP could not use his or her patient encounters from clinic A in calculating his or her individual patient volume. The intent of the flexibility for the proxy volume (requiring all EPs in the group practice or clinic to use the same methodology for the payment year) was to ensure against EPs within the same clinic/group practice measuring patient volume from that same clinic/group practice in different ways. The intent of these conditions was to prevent high Medicaid volume EPs from applying using their individual patient volume, where the lower Medicaid patient volume EPs then use the clinic volume, which would of course be inflated for these lower-volume EPs. CLINIC A (with a fictional EP and provider type)" EP #1 (physician): individually had 40% Medicaid encounters (80/200 encounters)" EP# 2 (nurse practitioner): individually had 50% Medicaid encounters (50/100 encounters)" Practitioner at the clinic, but not an EP (registered nurse): individually had 75% Medicaid encounters (150/200)" Practitioner at the clinic, but not an EP (pharmacist): individually had 80% Medicaid encounters (80/100)" EP #3 (physician): individually had 10% Medicaid encounters (30/300)" EP #4 (dentist): individually had 5% Medicaid encounters (5/100)" EP #5 (dentist): individually had 10% Medicaid encounters (20/200) In this scenario, there are 1200 encounters in the selected 90-day period for Clinic A. There are 415 encounters attributable to Medicaid, which is 35% of the clinic's volume. This means that 5 of the 7 professionals would meet the Medicaid patient volume criteria under the rules for the EHR Incentive Program. (Two of the professionals are not eligible for the program on their own, but their clinical encounters at Clinic A should be included.) The purpose of these rules is to prevent duplication of encounters. For example, if the two highest volume Medicaid EPs in this clinic (EPs #1 and #2) were to apply on their own (they have enough Medicaid patients to do that), the clinic's 35% Medicaid patient volume is no longer an appropriate proxy for the low-volume providers (e.g., EPs #4 and #5). If EP #2 is practicing part-time at both Clinic A, and another clinic, Clinic B, and both Clinics are using the clinic-level proxy option, each such clinic would use the encounters associated with the respective clinics when developing a proxy value for the entire clinic. EP #2 could then apply for an incentive using data from one clinic or the other. Similarly, if EP #4 is practicing both at Clinic A, and has her own practice, EP # 4 could choose to use the proxy-level Clinic A patient volume data, or the patient volume associated with her individual practice. She could not, however, include the Clinic A patient encounters in determining her individual practice's Medicaid patient volume. In addition, her Clinic A patient encounters would be included in determining such clinic's overall Medicaid patient volume.
For more information about the Medicare and Medicaid EHR Incentive Program, please visit http://www.cms.gov/EHRIncentivePrograms.
For the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs, should patient encounters ...
- Yes. EPs who practice in multiple locations must have 50 per... (more)
- Yes. EPs who practice in multiple locations must have 50 percent or more of their patient encounters during the reporting period at a practice/location or practices/locations equipped with certified EHR technology. Every patient encounter in all Places of Service (POS) except a hospital inpatient department (POS 21) or a hospital emergency department (POS 23) should be included in the denominator of the calculation, which would include patient encounters in an ambulatory surgical center (POS 24). For more information about the Medicare and Medicaid EHR Incentive Program, please visit http://www.cms.gov/EHRIncentivePrograms
Are Computerized Provider Order Entry (CPOE) and
Clinical Decision Support (CDS) required objectives under...
- ... (more)
2017 OPPS final rule, we finalized the elimination of the CPOE and CDS
objectives and associated measures for eligible hospitals and Critical Access
Hospitals (CAHs) attesting under the Medicare EHR Incentive Program for CY 2017
and subsequent years. The elimination of the CPOE and CDS objectives and
associated measures also applies to dual-eligible hospitals that are attesting
to CMS for both the Medicare and Medicaid EHR Incentive Programs.
2017 MIPS final rule, we did not include CPOE and CDS objectives and associated
measures as part of the advancing care information performance category, thus,
they are not required for reporting by MIPS eligible clinicians.
and CDS objectives and measures are still required for the Medicaid EHR
Incentive Program to successfully attest to meaningful use.
If an eligible professional (EP) sees a patient in a setting that does not have certified electronic health...
- Starting in 2013, an EP must have access to Certified EHR Technology at a locati... (more)
- Starting in 2013, an EP must have access to Certified EHR Technology at a location in order to include patients seen in locations in the determination of whether they meet the threshold of 50% of patient encounters at locations equipped with Certified EHR Technology to be eligible for the EHR Incentive Program. However, if the EP meets this threshold and also includes information on patient encounters at locations where they do not have access to Certified EHR Technology, information about those encounters can be included when calculating the numerators and denominators for the meaningful use measures.
For information about the patient encounters threshold, please visit FAQ 3215.
For more information about the Medicare and Medicaid EHR Incentive Program, please visit http://www.cms.gov/EHRIncentivePrograms
Due to recent law, we are
revising our policy on scribes for the Medicare and Medicaid EHR Incentives
- The 21st Century Cures Act amended... (more)
- The 21st Century Cures Act amended The Health Information Technology for Economic and Clinical Health Act (title XIII of division A of Public Law 111–5) by adding section 13103(c) which allows a physician (as defined in section 1861(r)(1) of the Social Security Act) to “delegate electronic medical record documentation requirements specified in regulations promulgated by the Centers for Medicare & Medicaid Services to a person performing a scribe function who is not such physician if such physician has signed and verified the documentation” and the action is in accordance with applicable State law.
Previously the Medicare and Medicaid EHR Incentive Programs did not specify the documentation requirements.
For additional information on electronic medical record documentation, please refer to other CMS requirements such as the Medicare physician fee schedule as well as FAQ 19061 (https://questions.cms.gov/faq.php?id=5005&faqId=19061.
For the Medicaid EHR Incentive Programs, when a patient is only seen by a member of the eligible profession...
- The EP can include o... (more)
- The EP 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 their own right (NPs and certain physician assistants (PA), 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. For more information about the Medicaid EHR Incentive Program, please visit http://www.cms.gov/EHRIncentivePrograms
What provisions are there for tribal clinics to receive payments from the Medicaid Electronic Health Record...
- Clinics are not eligible for EHR incenti... (more)
- Clinics are not eligible for EHR incentive payments. However, eligible professionals who qualify for an EHR incentive payment may reassign that payment to the taxpayer identification number (TIN) of their employer, if they so choose. You are correct that eligible professionals must choose the Medicaid EHR Incentive Program, and may not simultaneously receive payments from both programs if they qualify for both. They may make a one-time switch after having received an incentive payment, but the switch must occur before 2015.
For more information about the Medicaid EHR Incentive Program, please visit http://www.cms.gov/EHRIncentivePrograms"