No requirement for EHR to gather numerator and denominator
There is a little known but potential Stage 1 Meaningful Use nightmare for Eligible Professionals (EPs) who are preparing for Meaningful Use attestation for the CMS EHR incentives. The attestation process requires the inputting of numerators and denominators documenting the meaningful use of each percentage based measure. You can read more about this process from CMS Attestation User Guide for EPs
So where exactly to the numerators and denominators come from? More than likely your Complete Certified EHR will gather this data for your automatically but if that isn’t the case it will be up to the EP to arrive at these numbers. It may be hard to believe but this is correct for Stage 1 certified EHRs. There is no requirement for the EHR to gather this data. You can read it in black and white from the NIST Test Procedures: “The Vendor-supplied numerator and denominator information may be recorded automatically by the EHR,or recorded by the user in the EHR.” The only requirement is that there must be input fields for the EP to put in the numbers. No telling what workflow the EP will have to use to gather the data. Without the data they are not eligible for any incentives, period.
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Hopefully, Stage 2 will address this issue and require automatic aggregation of this critical data.
Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. As one hospital CEO stated, “we were notified by CMS that the adverse audit decision was being overturned and we did not have to return the 2011 EHR Incentive Payment. I would recommend the services of Mr. Tate and EMR Advocate in the event your facility is notified that it will be subject to a Meaningful Use audit or your facility is audited, or you have an adverse outcome and need to file an appeal." He blogs at Meaningful Use Audits. If you are a hospital with a question about the MU audit and appeal process, email him at: [email protected]
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