Patient Encounter in the World of Meaningful Use
The CMS EHR Incentive Programs are now in full swing and numerous eligible professionals have already received substantial Stage 1 Meaningful Use payments. HIT adoption, fueled by rewarding the “meaningful use of certified technology”, is moving forward as planned. However, there are still a few outstanding items that can cause difficulty for some EPs, especially specialists.
Much of the documentation and attestation of “meaningful use” is based on “patient encounters”. Well, what exactly is a patient encounter? This is obvious for an internist or general practitioner. Not so obvious for others.
This has been one of the most perplexing questions for specialists. If a patient is referred to an Ambulatory Surgical Center and a gastroenterologist performs a colonoscopy, is that a patient encounter? What about when a radiologist reviews and provides an impression of an image? How about when a cardiologist is called in to review an EKG but never sees the actual patient? If these events are classified as patient encounters that could be very problematic for specialists because in these scenarios it might be difficult to meet numerous MU measures simply because they might not have access to the type of data required for these patients to document meaningful use. Such EP measures as Vitals, Problem List, Medication Allergy List, etc. might be impossible to meet for these patients because the specialist would not have access to that type of information. If these patients must be included in the denominator of meaningful use calculations, that would spell failure for many attempts by specialists to obtain the CMS incentives.
At long last CMS has issued some very good and flexible guidance on the issue of what constitutes a patient encounter. CMS states: ”
All cases where the EP and the patient have an actual physical encounter with the patient in which they render any service to the patient should be included in the denominator as seen by the EP. Also a patient seen through telemedicine would still count as a patient “seen by the EP.” However, in cases where the EP and the patient do not have an actual physical or telemedicine encounter, but the EP renders a minimal consultative service for the patient (like reading an EKG), the EP may choose whether to include the patient in the denominator as “seen by the EP” provided the choice is consistent for the entire EHR reporting period and for all relevant meaningful use measures. For example, a cardiologist may choose to exclude patients for whom they provide a one-time reading of an EKG sent to them from another provider, but include more involved consultative services as long as the policy is consistent for the entire EHR reporting period and for all meaningful use measures that include patients “seen by the EP.” EPs who never have a physical or telemedicine interaction with patients must adopt a policy that classifies as least some of the services they render for patients as “seen by the EP” and this policy must be consistent for the entire EHR reporting period and across meaningful use measures that involve patients “seen by the EP” — otherwise, these EPs would not be able to satisfy meaningful use, as they would have denominators of zero for some measures.”
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