CMS Updates FAQs on Participation in EHR Incentive Programs

CMS has recently updated three FAQs providing clarification on how to attest to certain EHR Meaningful Use program objectives and measures. View the updated FAQs and answers below:

Question: When reporting on the Summary of Care objective in the EHR incentive program, which transitions would count toward the numerator of the measure?

Answer: A transition of care is defined as the movement of a patient from one setting of care (hospital, ambulatory, primary care practice, long-term care, home health, rehabilitation facility) to another. To count toward the Summary of Care objective for providers sharing access to an EHR, the transition or referral may take place between providers with different billing identities such as a different National Provider Identifier (NPI). Read more detail here.

Question: If an eligible professional in the EHR incentive program is part of a group practice that has achieved ongoing submission to a public health agency, but the EP himself did not administer any immunizations to any populations for which data is collected by their jurisdictions immunization registry during their EHR reporting period, can he attest to meeting the measure since they are part of the group practice that is submitting data to the registry?

Answer: If a provider does not administer immunizations, they should not attest to the measure; they must claim the exclusion. If a provider does administer immunizations but did not have any for a particular EHR reporting period, they are not required to claim the exclusion as long as they have done any necessary registration and testing and are reporting when they do have the data to report.

Question: When the denominator for measures used to calculate Meaningful Use in the EHR incentive programs is restricted to patients seen during the EHR reporting period, is the numerator also restricted to activity during the EHR reporting period or can actions for certain meaningful use measures be counted in the numerator if they took place after the EHR reporting period has ended?

Answer: The criteria for a numerator is not constrained to the EHR reporting period unless explicitly stated in the numerator statement for a given meaningful use measure. Read more detail.