CMS Issues More Answers to EHR Incentive Program Questions

Question: Can EPs who are not anesthesiologists, pathologists and radiologists apply for the exception for lack of face to face patient interaction and lack of need for follow-up?

Answer FAQ #7691: Yes this exception is open to any EP who meets both of these criteria (lack of face to face interactions and lack the to follow up with patients). We consider lack of face-to-face and need for follow up care to be situations where the EP has no or nearly no face to face patient interactions or need for follow up care. The EP would need to demonstrate either a complete lack of face-to-face interactions and follow-up or that cases of face-to-face interaction and follow-up are extremely rare and not part of normal scope of practice for that EP. EPs need to apply no later than July 1, 2014 to avoid the payment adjustment in 2015 although we encourage EPs to apply well before the deadline.

Question: Does the inclusion of certified Medical Assistant in the list of professionals who can enter orders into the EHR using CPOE and have them count in the numerator?

Answer FAQ #7693: We have revised the description of who can enter orders into the EHR and have it count as CPOE and have it count for purposes of the CPOE measure. This revision is available for EHR reporting periods in 2013 and beyond regardless of what stage of meaningful use the provider is attesting to.

Question: If I am participating in the Medicaid EHR Incentive Program but also provide care to Medicare patients, am I subject to the Medicare payment adjustments? Read the answer here.

Answer FAQ #7727:  Yes. While there are no payment adjustments under the Medicaid EHR Incentive Program, those Medicaid EPs who are also paid under Medicare could be subject to payment adjustments if they are not meaningful EHR users for an applicable reporting period. Adopting, implementing and upgrading EHR technology is not considered meaningful use for these purposes.