Updated FAQs on EHR Incentive Program
The Centers for Medicare & Medicaid (CMS) maintains a FAQ database on questions submitted for answers having to do with provider programs. From time to time more guidance or rule changes occur to necessitate updated answers in the database. Here are some of the latest updates to questions from the database in the EHR Incentive Program category.
Question: Do States need to verify the “installation” or “a signed contract” for adopt, implement, or upgrade (AIU) in the Medicaid EHR Incentive Program?
Answer: States should make clear to providers when they attest for AIU what documentation they must maintain, and for how long, in case of audit. If States determine that certain provider types are a high risk for potential fraud/abuse for AIU, then they can ask for some verification of adopting, implementation or upgrading but CMS encourages that this be done in a targeted manner, with the most electronic and simple means possible and not in such a way that would be burdensome to providers. For AIU, a provider does not have to have installed certified EHR technology. Read the complete answer.
Question: For Stage 1 and 2 meaningful use objectives of the Medicare and Medicaid 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?
Answer: 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. Read the complete answer.
Question: For the Stage 2 meaningful use objective of the Medicare and Medicaid EHR Incentive Programs that requires the successful electronic exchange of a summary of care document with either a different EHR technology or the CMS designated test EHR, if multiple eligible professionals (EPs) are using the same certified EHR technology across several physical locations, can a single test meet the measure?
Answer: The Stage 2 Final Rule (CMS-0044-F) changed the way shared Certified EHR Technologies are handled for the Stage 2 measure option for summary of care records at transitions of care and referrals. 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. Read the complete answer.
Question: In calculating the meaningful use objectives requiring patient action, if a patient sends a message or accesses his/her health information made available by their eligible professional (EP), can the other EPs in the practice get credit for the patient’s action in meeting the objectives?
Answers: Yes. This transitive effect applies to the Secure Messaging and the 2nd measure of the Patient Access (View, Download and Transmit) core objectives. Read the complete answer.
Question: When reporting on the Summary of Care objective in the EHR Incentive Program, which transitions would count toward the numerator of the measures?
Answer: A transition of care is defined as the movement of a patient from one setting of care (hospital, ambulatory, primary care practice, ambulatory specialty care practice, long-term care, home health, rehabilitation facility) to another. To count toward the Summary of Care objective, the transition or referral must take place between providers with different billing identities such as a different National Provider Identifier (NPI) or hospital CMS Certification Number (CCN). Read the complete answer.
