The Centers for Medicare and Medicaid Services' EHR Incentive Program Web site contains a variety of information for providers seeking incentive payments for meaningful use of electronic health records. Among the features is a Frequently Asked Questions page that as of mid-November had answers to 106 questions. Here's a sample:

Question: How will eligible professionals (EPs) and eligible hospitals apply for incentives under the Medicare and Medicaid Electronic Health Record (EHR) Incentive Program?

Answer: Information on registration for EHR incentive programs will be available toward the end of 2010 on our website at http://www.cms.gov/EHRIncentiveProgram. Registration for the Medicare EHR Incentive Program will begin in January 2011 and will be available online. Registration for the Medicaid EHR Incentive Program may also begin in January 2011, but the timing will vary by State.

Question: A number of measures for Meaningful Use objectives for eligible hospitals and critical access hospitals (CAHs) include patients admitted to the Emergency Department (ED). Which ED patients should be included in the denominators of these measures for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs?

Answer: Our intent is to include in the denominator visits to emergency departments (EDs) of sufficient duration and complexity that all of the Meaningful Use objectives for which the ED is included would be relevant. We also want to encourage integration of the inpatient and emergency departments by including inpatient admissions that occur through the ED. Therefore, we are clarifying the following specifications for including ED services in the denominator for measures associated with Stage 1 of Meaningful Use objectives for eligible hospitals and critical access hospitals (CAHs): 

    * The patient is admitted to the inpatient setting through the ED.  In this situation, the orders entered in the ED using certified EHR technology would count for purposes of determining the computerized provider order entry (CPOE) Meaningful Use measure.  Similarly, other actions taken within the ED would count for purposes of determining Meaningful Use

    * The patient initially presented to the ED and is treated in the ED's observation unit or otherwise receives observation services. Details on observation services can be found in the Medicare Benefit Policy Manual, Chapter 6, Section 20.6.

Question: Who can enter medication orders in order to meet the measure for the computerized provider order entry (CPOE) meaningful use objective under the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs? When must these medication orders be entered?

Answer: Any licensed healthcare professional can enter orders into the medical record for purposes of including the order in the numerator for the measure of the CPOE objective if they can enter the order per state, local, and professional guidelines. The order must be entered by someone who could exercise clinical judgment in the case that the entry generates any alerts about possible interactions or other clinical decision support aides. This necessitates that CPOE occurs when the order first becomes part of the patient's medical record and before any action can be taken on the order. Each provider will have to evaluate on a case-by-case basis whether a given situation is entered according to state, local, and professional guidelines, allows for clinical judgment before the medication is given, and is the first time the order becomes part of the patient's medical record.

Question: In a group practice, will each provider need to demonstrate meaningful use in order to get Medicare and Medicaid electronic health record (EHR) incentive payments or can meaningful use be calculated or averaged at the group level?

Answer: Yes. Medicare and Medicaid incentive payments are made on a per EP basis, not by practice. Each EP will need to demonstrate the full requirements of meaningful use in order to qualify for the EHR incentive payments. We made this clear in the preamble to the final rule when we declined to adopt alternative means for demonstrating meaningful use on a group-practice level (75 FR 44437).

The FAQs and additional information are available at https://www.cms.gov/EHRIncentivePrograms/.

--Joseph Goedert

 

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