Certified EHR Software and Meaningful Use Exclusions

Jim Tate, Meaningful Use Expert

Question Two from Specialists about Meaningful Use

Last week we took a look a the most common question from Specialists about meaningful use. This week we hope to put the final nail in the coffin of the second most common question I have received from specialists about meaningful use. “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.

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.” You can read more details from CMS here. Any questions?

Jim Tate is a nationally recognized expert on the CMS EHR Incentive Program, certified technology and meaningful use and author of The Incentive Roadmap® The Meaningful Use of Certified Technology: Stage 1.