The Centers for Medicare and Medicaid Services has published three new frequently asked questions about the electronic health records meaningful use incentive program. The new FAQs clarify the status of certified EHRs under certain circumstances:

If an eligible provider (EP) practices at an outpatient location, a location other than an inpatient (place of service 21) or emergency department (place of service 23), and that location is only equipped with Certified Electronic Health Records (EHR) Technology certified to the criteria applicable to an inpatient setting, must the EP include that location in their meaningful use calculations?

No, this location is not equipped with Certified EHR Technology with all the capabilities necessary for an EP to satisfy the meaningful use objectives and measures. Accordingly, this location would not be used to calculate whether the EP’s outpatient encounters meet the 50 percent threshold, nor would it be included in the calculations of the EP’s meaningful use measures.

However, an EP can consider the location equipped with Certified EHR Technology if they have access to Certified EHR Technology certified to the criteria applicable to an ambulatory setting, which fills the gaps between inpatient and ambulatory. FAQ#3077 explains access to Certified EHR Technology, and ONC FAQ #6-12-025-2 outlines the gaps between inpatient and ambulatory Certified EHR Technology.

If the EP chooses to equip the location with Certified EHR Technology with the applicable criteria, the EP must then include that location in all calculations including both the 50 percent threshold calculation and the meaningful use measures calculations.

If an eligible provider (EP) practices at an outpatient location that has not implemented all the functionalities necessary for the EP to meet meaningful use, is that location considered equipped with Certified Electronic Health Records (EHR) Technology? Must that location be included in the EP’s meaningful use calculations? Does it matter if the location possesses ambulatory Certified EHR Technology covering the relevant meaningful use objectives, but does not implement them?

No, this location is not equipped with Certified EHR Technology and should not be used to calculate whether the EP’s outpatient encounters meet the 50 percent threshold, nor would it be included in the calculations of the EP’s meaningful use measures. This is true even if the location does possess ambulatory Certified EHR Technology covering the relevant meaningful use objectives, but does not implement the functionalities.

An EP can consider the location equipped with Certified EHR Technology only if they have access to Certified EHR Technology certified to the criteria applicable to an ambulatory setting, which fills the gaps between the technology implemented by the location and the Certified EHR Technology necessary to meet the relevant meaningful use objectives. If the EP chooses to equip the location with Certified EHR Technology with the applicable criteria, the EP must then include this location in all calculations including both the 50 percent threshold calculation and the meaningful use measures calculations.
 
When combining meaningful use data from multiple locations equipped with Certified Electronic Health Records (EHR) Technology, is it required to have a full meaningful use report from each location or is it acceptable to only collect denominator information from one or more locations?

An eligible provider (EP) must have accurate denominators for the meaningful use measures. If an EP is unable to access data from a location to determine whether a patient or action in the denominator should be included in the numerator for a given measure, the EP should be aware that this could negatively impact their performance on the measure, and   the EP might not meet the required threshold for the measure.

FAQ pages for meaningful use and more than 20 other CMS programs are available at https://questions.cms.gov/.

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