No requirement for EHR to gather numerator and denominator
There is a little known but potential Stage 1 nightmare for EPs as they prepare for Meaningful Use attestation for the CMS EHR incentives. The attestation process as described in the CMS Attestation User Guide for EPs requires the inputting of numerators and denominators documenting the meaningful use of each percentage based measure.
Where do these numbers come from? If you are lucky your Complete Certified EHR will gather this data for your automatically. If you are not so lucky it is TOTALLY up to the EP to arrive at these numbers. Hard to believe but this is correct for Stage 1 certified EHRs. There is no requirement for the EHR to gather this data. Here it is in black and white from the NIST Test Procedures: “The Vendor-supplied numerator and denominator information may be recorded automatically by the EHR,or recorded by the user in the EHR.” The only requirement is that there must be input fields for the EP to put in the numbers. No telling what workflow the EP will have to use to gather the data. Without the data they are not eligible for any incentives, period.
Hopefully, Stage 2 will address this issue and require automatic aggregation of this critical data.
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