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MIPS Twitter Roundup – MACRA Monday

Posted on December 11, 2017 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

As we near the end of 2017, I found a number of tweets from CMS and other people that I thought would be useful to those that are interested in MACRA and MIPS.

First up is this tweet from CMS that it’s not too late to still participate in MIPS and collect some performance data before the end of 2017. This is them promoting the Test Option which would allow you to avoid the 4% penalty:

Next up is a fact sheet from CMS which outlines the different between 2017 and 2018 when it comes to MACRA/MIPS. I particularly like page 6 of the document. As you go through it, you’ll realize why 2018 is going to be much harder than 2017.

Next up is a stat from MGMA. I’d be interested in learning about the 14% of practices that think that their value-based reimbursement is going to decrease. Are these people going to direct primary care? I don’t see it going down for almost anyone. What do you think?

Finally, Matt Fisher asks a question about whether MIPS should be voluntary. I don’t think they can make it any more voluntary given the current legislation and do any of us think that congress is going to take up this topic? I don’t. So, it’s kind of a moot point. However, there is a lot of doctor angst about MIPS/MACRA. I just don’t see enough of it to really move the needle on things. I think we’re stuck with MACRA/MIPS for the forseeable future.

In The Hot Seat Again: eClinicalWorks Faces Billion-Dollar Suit Over Alleged Software Problems

Posted on November 27, 2017 I Written By

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. Contact her at @ziegerhealth on Twitter or visit her site at Zieger Healthcare.

Earlier this year, eClinicalWorks agreed to pay $155 million to the U.S. Department of Justice to resolve allegations that it had faked its conformance with Meaningful Use criteria. The DoJ suit alleged that by withholding information needed for certification, eCW violated the False Claims Act.

Now, the vendor is facing what could be an even more serious legal threat, according to a news report appearing in Becker’s Hospital Review. BHR is reporting administrator of the estate of a deceased cancer patient is suing the vendor over data display errors that may have affected the patient’s care.

What makes the stakes so high in this case is that the complaint is asking the court to certify the case as class action, with members to include “all persons residing in the United States whose physicians used eCW to record and store their medical records at all dates relevant.” The suit is asking the court to award plaintiffs $999 million in damages, Becker’s Hospital Review reports.

According to the complaint, which was filed by Kristina Tot, administrator of the estate of the deceased Stjepan Tot, errors with eCW software began to appear before the cancer patient’s death. For example, “he was unable to display his medical history or progress notes,” the complaint reportedly states.

The cancer patient’s problems were far from unique, however, the suit asserts. According to the complaint, important eCW software functions didn’t work or violated regulatory guidelines. The filing claims the vendor didn’t provide accurate and reliable health information, displayed incorrect panels and didn’t record EHR user actions in audit logs.

The bottom line, the suit claims, is that millions of patient records were compromised, leaving patients and physicians unable to rely on the eCW platform.

I am not qualified to speak on whether there’s any merit to the latest suit against eCW, though I think it’s reasonable to assume that the company may not have its act together. (You might also want to check out the angry eCW critiques on this site — whose publisher, like our fearless leader John Lynn, I know to have an impeccable reputation for honesty.)

Ultimately, it’s hard to say whether this latest suit is largely blowback from the previous certification problem or yet another (extremely) costly headache. Either way, if I were part of its leadership team I’d be more than a little shaken by recent events even if the recent complaint gets dismissed.

MIPS Penalties Include Medicare Part B Drugs – MACRA Monday

Posted on November 13, 2017 I Written By

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

I’m sure most regular readers can tell that we’re pretty worn out and tired of MACRA, MIPS, and related government regulation. No doubt you’ll see us posting fewer MACRA Mondays going forward, but we’ll still try to cover major MACRA events as they occur. We just won’t be publishing MACRA Monday every Monday like we’ve been doing.

Jim Tate recently posted about the Real MIPS Timeline which included:

  • Phase 1 – Denial
  • Phase 2 – Shock/Anger
  • Phase 3 – Acceptance

You should read his full writeup, but he’s right. There’s a lot of denial that’s going to lead to shock and anger until the majority of healthcare have to finally accept that MIPS and MACA aren’t going anywhere.

Jim Tate also wrote another important piece related to the MIPS penalties and Medicare Part B drugs. You can read the full details of the change, but for those too lazy to click over, here’s the summary:

  • Many organizations argued that Medicare Part B Drug Costs Shouldn’t be Included in the MIPS Penalties (I mean…payment adjustments)
  • The MACRA Final rule still includes Medicare Part B drug costs (for the majority of people) in the MIPS reimbursement and eligibility calculations

If you’re a practice with a high volume of part B drugs, you better start figuring out your MIPS strategy now! Otherwise, that payment adjustment is going to hit pretty hard.

Thanks Jim for the great insights into MACRA and MIPS. If you need help with MIPS, be sure to check out Jim’s company MIPS Consulting.

MACRA Twitter Roundup – MACRA Monday

Posted on October 30, 2017 I Written By

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

We took last week off from our MACRA Monday series of blog posts. It seems like we’re in a kind of lull period for the program. Either you’ve started collecting the data you’ve needed or you haven’t. Plus, we’re kind of waiting for the next MACRA Final rule to drop for more details.

With that in mind, I did want to see what some of the latest things that were being shared on Twitter when it comes to MACRA. I found a lot of strong opinions about the program, some good resources, and some forward-looking thoughts on what could be coming in the next MACRA final rule.


It’s hard to argue with John. Not just because he’s a smart guy, but because he’s right that it’s hard to imagine a path forward that’s fee for service and doesn’t include a shift to value based care in some form or fashion. At least given the current market dynamics.


This caution from Workflow Chuck should have us all nervous about the shift. I see a lot of healthcare organizations going after the target as opposed to the goal of value based care.


MACRA is going to impact your biz. I liked the way Kelly broke it out into 4 areas. No doubt some of these things could be argued both ways.


This is still how most doctors I know feel about MACRA and even meaningful use before it. They feel like they’ve been thrown under the bus.

Here are two forward looking resources that look at what we might get from the MACRA Final Rule:

What else are you hearing about MACRA? Would love to hear your thoughts, insights, questions, perspectives, rants, etc in the comments.

Optimizing Your EHR for MIPS and Other Quality Payment Programs – MACRA Monday

Posted on October 9, 2017 I Written By

The following is a guest blog post by Meena Ande currently acts as Director of Implementation for Advantum Health. This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

As quality reporting requirements ramp up under value-based payment programs like MIPS, healthcare organizations are busy retrofitting their EHRs to make way for new measures. In some settings, not much has changed by way of tech utilization since initial EHR investments were made. Many outpatient settings still lack the internal expertise needed to optimize their implementations.

The truth is many EHRs have the functionality providers need for quality reporting, but many providers don’t know that due to limited exposure to the system. Couple that stunted tech knowledge with the well documented lack of familiarity with MACRA and the recent rise of the service model in healthcare is no surprise. Many practice administrators are relying on their EHR vendor or engaging outside experts to help lead the charge on system reconfiguration to meet Quality Payment Program demands.

There are several EMR capabilities providers can take advantage of to support QPP reporting efforts. Here are a few tips to keep in mind as you customize your EHR for MIPS and other value-based models.

Don’t boil the ocean when selecting CQMs.

Most EHRs give the option of tracking more than what is required for quality reporting. Initially, track applicable measures that exceed reporting requirements. After three to four weeks you’ll know which are your strong areas. Pick the best of the litter and proceed.

Providers can be overwhelmed by too many measures, particularly in multi-specialty practice settings. While it can be difficult to find overlap in measures between specialties, taking advantage of shared metrics whenever possible can reduce reporting burdens. Sit down as early as possible and develop an EHR configuration that works for your practice’s various clinicians.

Case in Point:

A gastroenterologist and a cardiologist may work in the same multi-specialty organization and on the same EHR, but the clinical quality measures they care about differ. There is no reason to give the gastroenterologist access to the cardiology problem list in the EHR. Specialty views improve ease-of-use and support more complete documentation.

Most EHRs offer role-based and specialty-based customization. Administrators can enable or disable EHR features related to some quality measures at the practice level and sometimes at the individual provider level. Clinical quality measures are based on details about the patient, but what is captured at each point of care should be tailored to the specific provider role.

Consider the roles impacted by different CQMs.

Keep the role of the person who may be responsible for different quality measures and Advancing Care Information workflows in mind when selecting and carving out space for CQMs in your EHR. Select measures that spread reporting work across multiple roles to relieve clinicians of unnecessary burdens.         

Case in Point:

The insurance eligibility verification required under Meaningful Use is managed by the front office. Front-office staff members should be made aware of the processes they need to complete before a patient checks in, and where to document that task in the EHR.

Control what is included in MIPS denominators.

Like Meaningful Use, patient encounter volume is important under MIPS. The size of the patient pool under any given quality measure directly impacts your adherence percentage. While most primary care encounters do meet patient visit requirements under MACRA, that is not always the case in specialty settings. Clinicians can exercise some control in determining what is included in patient denominators when reporting under MIPS.

Case in point:

Some primary care visits can be omitted. Let’s say a two-physician practice sees 50 patients a day. Only 15 of those patients might be seen by a physician. The rest of the patients may be there for a simple procedure like a blood pressure screening, stress test, or echocardiogram, where quality reporting elements are not verified. Such visits should be excluded.

Evaluate your reporting paths.

MIPS offers both EHR-based and registry-based reporting paths. Most specialties can submit CQM data via their EHR while others will have to rely on paid registry reporting. Additional reporting options might include submitting through associations that member clinicians are affiliated with, or through registries created by large hospital affiliates to help related providers.

Another hurdle for clinicians is deciding whether to submit data as a group or independently. Groups interested in participating in MIPS via the CMS web interface or administering the CAHPS for MIPS survey had until June 30, 2017, to register. Beyond that, clinicians have until the March 31, 2018, MIPS submission deadline to decide whether to report independently or as a group.

Case in point:

Big groups with different levels of EHR proficiency among providers may be better suited reporting at an individual level. Individual reporting takes more time for attestation, but the advantage is that higher-performing clinicians can avoid a penalty if the group doesn’t collectively meet reporting criteria.

Each month, sample 10 percent of EHR CQM data, including instances where criteria have been met and where it has not. Catch outliers with trouble following through on processes and extend targeted training to the team members bringing numbers down.

Conclusion

Optimizing the EHR and other tech resources providers have in place can be a huge MIPS enablement factor. Up-front customization work helps providers meet reporting requirements and save time over the long run. EHR optimization also enables future value-based care initiatives and lays the groundwork for population health management programs. Gains made in EHR use benefit the life of the practice through increased efficiency and, at the end of the day, better patient care.

About Meena Ande
Meena Ande currently acts as Director of Implementation for Advantum Health where she manages Implementation of services along with EHR optimization, with emphasis on workflow management for value-based reporting.

MACRA Preparation, Are You Ready? – MACRA Monday

Posted on October 2, 2017 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

I’ll admit that the timing of this week’s MACRA Monday is a bit rough for me given the tragedy that’s occurred in my town, Las Vegas. Instead of dwelling on the tragedy and the person who could do such an awful thing, it’s been amazing even in these early hours to see how many people in Las Vegas and around the world want to and are supporting the victims of this tragedy.

We heard that there was a need for blood and thought we could help. Turns out that hundreds of others had the same idea and the blood banks have their schedules full through Wednesday. We’ll go after that to replenish the blood banks that no doubt will take a while to replenish their supply.

Thanks to everyone on Facebook, Twitter, and other social media that have reached out to myself and the rest of us that live in Las Vegas. We’re in a bit of shock and it doesn’t feel real.

To keep with our tradition of MACRA Monday, I thought I could at least share this infographic from Integra Connect on how prepared specialty practices are for MACRA:

No doubt there are a lot of healthcare organizations that aren’t ready for MACRA and they are confused on how they should be ready. Hopefully, those who have read our weekly MACRA Monday posts feel better prepared than most. MACRA is upon us whether you’re ready or not. However, MACRA certainly seems much less important on this day of mourning in Las Vegas.

On this tragic day, it’s worth noting all the incredible stories I’ve heard about Las Vegas healthcare professionals that were prepared and ready for a tragedy like this. I read stories of UMC, a major Las Vegas hospital that was so full of victims that they asked to stop bringing people to UMC that didn’t have life-threatening injuries. I read of EMS people who were at home and went into the danger to help transport victims. No doubt there will be hundreds of other stories of heroism by healthcare professionals. Many that likely won’t be heard or seen, but saved people’s lives. We thank them for their preparation, care, and work that no doubt has saved hundreds of people’s lives.

A big thank you from Vegas to each of you for all of your support.

New EHR Certification Rules Including Self-Declaration – MACRA Monday

Posted on September 25, 2017 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

Elise Sweeney Anthony and Steven Posnack recently announced on the ONC Health IT Blog two major changes to the EHR certification program. In some ways, it shows a maturity of the EHR certification program, but in other ways, it’s ONC kind of taking a more hands off approach to EHR certification.

Here are the two big changes they made:

  1. Approving more than 50% of test procedures to be self-declaration; and
  2. Exercising discretion for randomized surveillance of certified health IT products.

The first one is really fascinating since they’re making 30 out of the 55 certification criteria as “self-declaration only.” That basically means that EHR vendors will just have to claim they meet the requirements. The ONC-ACBs won’t be certifying those 30 test procedures. In many ways, it reminds me of the meaningful use self-attestation. Does that mean that ONC-ACBs will cut their costs in half? Don’t be holding your breath on that one.

Let’s just hope that most EHR vendors don’t self-certify the way eCW approached EHR certification. Although, the eCW EHR certification issues are the perfect example of why a company self certifying their EHR software or the ONC-ACB certifying the EHR software is just about the same. I haven’t seen which test procedures will be self-declared, but my guess is that it was the ones that the ONC-ACBs weren’t really doing much to test and certify anyway. Ideally, this will free up the ONC-ACBs to dive deeper into the 25 test procedures they’ll still complete so they can avoid another eCW like incident.

Some might wonder why we don’t just take the self-declared EHR certification tests altogether if there’s no one that’s going to be checking them. What those people miss is that the self-declaration still keeps the EHR vendors on the hook for properly implementing the EHR certification criteria. If it’s discovered that they claimed to be compliant but aren’t, then the government can go after the EHR vendor for false claims.

The second change has me a little more puzzled. I’m not sure why they would want to release ONC-ACBs from the requirement to randomly audit EHR certifications. Maybe they didn’t discover any issues during their random audits and so they didn’t see a need to continue them. Or maybe the ONC-ACBs said they were going to pull out as certifying bodies if the government didn’t lighten the EHR Certification load. This is all conjecture, but they could be some of the reasons why ONC decided to make this change. They did offer the following insight into their reasoning:

This exercise of enforcement discretion will permit ONC-ACBs to prioritize complaint driven, or reactive, surveillance and allow them to devote their resources to certifying health IT to the 2015 Edition.

I wonder how many complaints the ONC-ACBs have gotten about the EHR software they’ve certified. Have they just been so overwhelmed with complaints that they need more time to deal with those complaints and so audits aren’t needed? I’d be surprised if this was the case. At this point I imagine most people with EHR certification issues will be calling the whistle blower attorneys, but I could be wrong.

All in all, I don’t think these EHR certification changes are a huge deal. It’s largely a maturing of the EHR certification program and does little to help the EHR certification burden on software vendors. Maybe the ONC-ACBs will charge a little less for their certification, but that’s always been a negligible cost compared to the development costs to become a certified EHR. I’m sure the ONC-ACBs are happy with these changes though.

What do you think of these changes? Any other impacts I haven’t described above that we should consider?

EHR Innovation & Regulation: Friends or Foes?

Posted on August 16, 2017 I Written By

The following is a guest blog post by Stephen Dart, Sr. Director of Product Management at AdvancedMD.

Healthcare insiders often point out how far behind the industry is in taking advantage of technology when compared to industries like retail or finance.

Technology providers get their share of blame for not designing it with a user in mind, a common argument heard in relation to the Electronic Health Record (EHR) ill-fitting place in the physician’s workflow. What is not talked about much is the role regulations play in shaping the technology and its use in healthcare.

Designing for compliance

Regulations are present in every industry and serve an important function of protecting individuals’ privacy and rights. Healthcare is highly regulated compared to many other industries due to the sensitive nature of Protected Health Information.  There is a good deal of additional regulations regarding programs such as MACRA, dedicated to monitoring provider performance and reporting it back to the government for reimbursement. As such, technology for providers must be designed to capture and report such data.

For vendors like AdvancedMD, one of the challenges is not in designing software to address the regulations, but rather in designing it under the ever-evolving guidelines and shifting deadlines. At times, well-meaning standards also fail to function as intended because they are not enforced end-to-end.

As an example, Meaningful Use Stage 2 required the EHR to meet a standard for interfacing with state immunization registries. For certification, technology providers had to produce a standard-format file and transmit it to the state immunization registry. However, every state had its own set of requirements and most states would not accept the format designated as the certification requirement but instead have their own additional or different requirements.

Consider lab results as another example. The EHR has to meet the engineering standard for using a LOINC code when receiving lab results to enable the physician to report metrics for regulatory attestation. Unfortunately, labs are not held to the same standard, and if the lab does not send results using the LOINC code, the physician cannot get credit when reporting or has to manually add a code for it to be considered for meeting the performance metric.

Naturally, there is cost incurred to design compliance features for vendors. At AdvancedMD, it has a significant impact on our research and development (R&D) budget. It also influences the other two R&D categories that have a direct impact on the end-user experience – keeping the technology on the cutting edge and innovation.

Integrating compliance into workflow

If regulations require physicians to report more data, vendors have a choice of designing compliance features to either ask the physician to input that information manually or to capture it automatically for reporting.

At AdvancedMD, a lot of effort goes into automating the regulatory requirements and integrating the necessary data collection naturally into providers’ existing workflow. If software identifies that the physician has just written an electronic prescription, there is no reason to ask him or her to go into a separate system and attest manually to having done so. This regulatory tracker can be natively built into the platform.

All roads lead to innovation

There is a lot of pressure on everyone in healthcare today and the industry is undergoing constant changes. Patients expect more as they pay more under high-deductible plans.  They increasingly rely on wearables to tell them how well they sleep and how many steps they need to take as part of a larger trend of taking command of their own health. Doctors and patients alike will benefit from this data being integrated into patient records.  If this patient-captured data can be merged into the patient chart, machine learning and analytics algorithms can in some cases predict what an independent practice needs to do next. This next step could be to streamline administrative processes for outreach messaging and improve care through electronic follow-up, leading to increased profitability and better care. Importantly, the EHR, practice management and all other technologies designed for providers need to liberate them to focus on patient care, not distract from it.

All these advanced features are the next frontier in healthcare and require vendors to dedicate a lot more effort and budget to innovation. While healthcare technology can’t be expected to catch up with an Apple or Facebook overnight with regard to user experience, there is much that can be done to close the gap. The industry as a whole will get there much faster when regulations and technology align to advance that goal.

Incremental regulatory steps in areas where standards can be controlled and enforced cradle-to-the-grave will benefit all parties. Vendors can plan their engineering budgets in advance and design fully functional compliance features. The industry will benefit from designing with the user in mind, furthering the role regulations play in shaping technology and its use in healthcare. Ultimately, regulations should allow providers to focus on care and to engage more meaningfully with their patients, thus optimizing the EHR’s role in the physician’s workflow.

Is ICSA Labs Getting Out of the EHR Certification Business?

Posted on April 18, 2017 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I got the following email that was received by ICSA customers:

Dear Valued Customer:

Your organization has received product testing and certification services as a customer of ICSA Labs, a division of MCI Communications Services, Inc., d/b/a Verizon Business Services (“ICSA Labs”).

I am writing to inform you that ICSA Labs will no longer be accepting new engagements for product testing and certification, or renewing expiring Statement(s) of Service. However, please be assured that we will continue to honor any existing, active Statements of Service that we may have with your organization, and to maintain any current certifications for the applicable term.

Thank you for your attention to this matter. If you have any questions, please contact icsalabsinfo@icsalabs.com.

Sincerely,

George Japak
ICSA Labs, Managing Director

Does this mean ICSA is withdrawing as an EHR Certifying body (ATCB)? I asked EHR certification expert, Jim Tate, which EHR certifying bodies remain if ICSA is pulling out and he said that right now Drummond, ICSA, InfoGard, and SLI are authorized to test and only Drummond, ICSA, and InfoGard are authorized to certify. You can find more details on the ONC website.

A part of me isn’t really surprised since the EHR certification business isn’t a great business. There are a limited number of clients and a limited amount of revenue available. Plus, under meaningful use, EHR certification became a commodity. That’s why CCHIT couldn’t survive. Seems like ICSA Labs is heading the same direction as CCHIT.

The bigger question I would ask is should EHR certification continue at all?

New EHR Incentive Program FAQs from CMS

Posted on November 10, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

On October 6, the Centers for Medicare & Medicaid Services (CMS) released the final rule with comment for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. To keep you informed of changes to the programs and how to participate in 2015, CMS has also released three new FAQs providing clarification on how to attest to certain measures for health information exchange, patient electronic access, and other objectives that require patient action.

FAQ 12817
Question: For the Health Information Exchange objective for meaningful use in 2015 through 2017, may an eligible professional (EP), eligible hospital or critical access hospital (CAH) count a transition of care or referral in its numerator for the measure if they electronically create and send a summary of care document using their CEHRT to a third party organization that plays a role in determining the next provider of care and ultimately delivers the summary of care document?

Answer: Yes. An EP, eligible hospital or CAH may count transmissions in this measure’s numerator when a third party organization is involved so long as:

  • The summary of care document is created using certified EHR technology (CEHRT);
  • The summary of care document is transmitted electronically by the EP, eligible hospital or CAH to the third party organization…read the full FAQ.

FAQ 12821
Question: If multiple eligible professionals or eligible hospitals contribute information to a shared portal or to a patient’s online personal health record (PHR), how is it counted for meaningful use when the patient accesses the information on the portal or PHR?

This answer is relevant to the following meaningful use objectives: Patient Specific Education and Patient Electronic Access measure 2.

Answer: If an eligible professional sees a patient during the EHR reporting period, the eligible professional may count the patient in the numerator for this measure if the patient (or an authorized representative) views online, downloads, or transmits to a third party any of the health information from the shared portal or online PHR. The same would apply for an eligible hospital or CAH if a patient is discharged during the EHR reporting period. If patient-specific education resources are provided electronically, it may be counted in the numerator for any provider within the group sharing the CEHRT who has contributed information to the patient’s record if that provider has the patient in their denominator for the EHR reporting period. The respective eligible professional, eligible hospital, or CAH must have contributed at least some of the information identified in the Medicare and Medicaid Programs; Electronic Health Record Incentive Program – Stage 3 and Modifications to Meaningful Use in 2015 Through 2017 final rule (80 FR 62807 through 62809) to the shared portal or online PHR for the patient. However, the respective provider need not have contributed the particular information that was viewed, downloaded, or transmitted by the patient. …Read the full FAQ.

FAQ 12825
Question: In calculating the meaningful use objectives requiring patient action, if a patient sends a message or accesses his/her health information made available by their eligible professional (EP), can the other EPs in the practice get credit for the patient’s action in meeting the objectives?

Answer: Yes. This transitive effect applies to the Secure Electronic Messaging objective, the 2nd measure of the Patient Electronic Access (View, Download and Transmit) objective, and the Patient Specific Education objective.

If a patient sends a secure message about a clinical or health related subject to the group practice of their EP, that patient can be counted in the numerator of the Secure Electronic Messaging measure for any of the EPs at the group practice who use the same certified electronic health records technology (CEHRT) that saw and patient during their EHR reporting period.

Similarly, if a patient views, downloads or transmits to a third party the health information that was made available online by their EP, that patient can be counted in the numerator of the 2nd Patient Electronic Access measure for any of the EPs in that group practice who use the same CEHRT and saw that patient during their EHR reporting period.

If patient-specific education resources are provided electronically, it may be counted in the numerator for any provider within the group sharing the CEHRT who has contributed information to the patient’s record if that provider has the patient in their denominator for the EHR reporting period. … Read the full FAQ.

For more information on accurately calculating the numerator for measures, please visit FAQ 8231.