CMS Issues Updates on EHR Incentive Questions

CMS EHR Incentive ProgramThe 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 (FAQ 9690): 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 for providers sharing access to an EHR, the transition or referral may 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.

Question (FAQ 11984): If an eligible professional (EP) in the EHR Incentive Programs is part of a group practice that has achieved ongoing submission to a public health agency (PHA), but the EP himself/herself did not administer any immunizations to any of the populations for which data is collected by their jurisdiction’s immunization registry during their EHR reporting period, can he/she attest to meeting the measure since they are part of the group practice that is submitting data to the registry?

Answer: If a provider does not administer immunizations, they should not attest to the measure; they must claim the exclusion. If a provider does administer immunizations, but did not have any for a particular EHR reporting period, they are not required to claim the exclusion as long as they have done any necessary registration and testing and are reporting when they do have the data to report. Read the complete answer.

Question (FAQ 8231): While the denominator for measures used to calculate meaningful use in the EHR Incentive Programs is restricted to patients seen during the EHR reporting period, is the numerator also restricted to activity during the EHR reporting period or can actions for certain meaningful use measures be counted in the numerator if they took place after the EHR reporting period has ended?

Answer: The criteria for a numerator is not constrained to the EHR reporting period unless expressly stated in the numerator statement for a given meaningful use measure. The numerator for the following meaningful use measures should include only actions that take place within the EHR reporting period: Preventive Care (Patient Reminders) and Secure Electronic Messaging.

For all other meaningful use measures, the actions may reasonably fall outside the EHR reporting period timeframe but must take place no earlier than the start of the reporting year and no later than the date of attestation in order for the patients to be counted in the numerator, unless a longer look-back period is specifically indicated for the objective or measure. This FAQ relates to prior program years and has been archived as of April 10, 2015.

See more CMS Updated FAQs previously published on the next pages.