There are two questions from Eligible Professional specialists about the CMS EHR Incentives that I’m asked over and over again.
Question 1: “Do specialists have to meet all of the required Core Set Meaningful Use objectives? We don’t do vitals, we don’t prescribe, we don’t ______ (fill in the blank).”
The Meaningful Use tablets that Moses brought down from Mount Sinai clearly state that: “To qualify for an incentive payment, 20 of these 25 objectives must be met. There are 15 required core objectives. The remaining 5 objectives may be chosen from the list of 10 menu set objectives.” That makes it sound like psychiatrists, chiropractors, radiologists, and other possible EPs must meet at least 20 of the objectives to be eligible for the Medicare incentives. However, that is not the case as there are exclusions available that can be claimed during attestation.
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Here are the meaningful use objectives that can be excluded from the Core Set based on certain requirements: CPOE, eRx, Vital Signs, Smoking Status, Electronic Copy of Health Information, and Clinical Summaries. Exclusions that may be claimed from the Menu Set include: Drug Formulary Checks, Clinical Lab Test Results, Patients Reminders, Patient Electronic Access, Medication Reconciliation, Summary Care Record, Immunization Registries Data Submission, and Syndromic Surveillance Data Submission. The exclusion requirements for each objective is available at CMS. I hope that answers the question about possible exclusions.
Question 2: “If I can exclude Meaningful Use objectives, do I still have to have certified software for that module?”
So, here is the issue, plain and simple. If a radiologist, psychiatrist, or dentist doesn’t perform vitals on their patient, they can exclude that meaningful use objective. Even though “vitals” is a Core Measure, it can still be excluded. So far, so good. But does the EP, who has excluded a Core Measure, or not selected a Menu Measure, still have to possess that certified technology that covers the excluded or not selected Measure?
In perhaps the most extreme example the question is whether a chiropractor, who cannot legally prescribe mediation, still has to possess certified prescribing technology to be eligible for the incentives? The answer is “yes”. It doesn’t matter what an EP can exclude, or not select, they still must have “complete certified EHR technology“. That means everything, all modules whether they are being used or not.
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CMS guidance is very clear on this issue. Here is what they say: “we consider ‘possessing’ (or ‘having’) Certified EHR Technology to include either the physical possession of medium on which a certified Complete EHR or combination of certified EHR Modules resides, or a legally enforceable right by an eligible health care provider to access and use, at its discretion, the capabilities a certified Complete EHR or combination of certified EHR Modules includes.”
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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