CMS Has New FAQs for You about the EHR Incentive!

We want to keep you updated with the latest information on the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. Last week, we sent you a message highlighting some of the new FAQs that have been posted to the CMS website. Take a minute and review the remaining new FAQs on eligibility, certified EHR technology, meaningful use, and attestation.
The new FAQs on eligibility are:
1.     If I am receiving payments under the CMS Electronic Prescribing (eRx) Incentive Program, can I also receive Medicare and Medicaid EHR incentive payments? Read the answer.
2.     Can EPs participate in the 2011 Physician Quality Reporting System (formerly called PQRI), 2011 Electronic Prescribing (eRx) Incentive Program, and the EHR Incentive Program (aka Meaningful Use) at the same time and earn incentives for each? Read the answer.
The new FAQs on certified EHR technology are:
1.     If a provider feeds data from certified EHR technology to a data warehouse, can the provider report on Meaningful Use objectives and clinical quality measures from the data warehouse? Read the answer.
2.     For the Medicare and Medicaid EHR Incentive Programs, is an EP or eligible hospital limited to demonstrating meaningful use in the exact way that EHR technology was tested and certified? For example, if a Complete EHR has been tested and certified using a specific workflow, is an EP or eligible hospital required to use that specific workflow when it demonstrates meaningful use? Read the answer.
3.     If data is captured using certified EHR technology, can an EP or eligible hospital use a different system to generate reports used to demonstrate meaningful use for the Medicare and Medicaid EHR Incentive Programs? Read the answer.
The new FAQs on meaningful use are:
1.     If my certified EHR technology is capable of submitting batch files to an immunization registry using the standards adopted by the Office of the National Coordinator of Health Information Technology (HL7 2.3.1 or 2.5.1, and CVX), is that sufficient to meet the Meaningful Use objective "submit electronic data to immunization registries" for the Medicare and Medicaid EHR Incentive Programs? Read the answer.
2.     If a State utilizes the option to include patient panels when looking at patient volume for the Medicaid EHR Incentive Program, what does it mean to have "unduplicated encounters"? Read the answer.
3.      Do specialty providers have to meet all of the meaningful use objectives for the Medicare and Medicaid EHR Incentive Programs, or can they ignore the objectives that are not relevant to their scope of practice? Read the answer.
4.     For the Medicare and Medicaid EHR Incentive Programs, does an eligible hospital have to count patients admitted to both the inpatient and emergency departments in the denominator of meaningful use measures, or can they count only emergency department patients? Read the answer.
5.     For the Medicare and Medicaid EHR Incentive Programs, should patient encounters in an ambulatory surgical center (Place of Service 24) be included in the denominator for calculating that at least 50 percent or more of an EP's patient encounters during the reporting period occurred at a practice/location or practices/locations equipped with certified EHR technology? Read the answer.
6.     To meet the meaningful use objective "use computerized provider order entry (CPOE)" for the Medicare and Medicaid EHR Incentive Programs, should EPs include hospital-based observation patients (billed under POS 22) whose records are maintained using the hospital's certified EHR system in the numerator and denominator calculation for this measure? Read the answer.
7.     If an EP sees a patient in a setting that does not have certified EHR technology but enters all of the patient's information into certified EHR technology at another practice location, can the patient be counted in the numerators and denominators of meaningful use measures for the Medicare and Medicaid EHR Incentive Programs? Read the answer.
8.     Do controlled substances qualify as "permissible prescriptions" for meeting the electronic prescribing (eRx) meaningful use objective under the Medicare and Medicaid EHR Incentive Programs? Read the answer.
The new FAQ on attestation is:
1.     How will I attest for the Medicare and Medicaid EHR Incentive Programs?Read the answer.
We will keep you informed of future updates to our FAQs throughout the duration of the CMS EHR Incentive Programs.
Want more information about the EHR Incentive Programs?
Make sure to visit the CMS EHR Incentive Programs website for the latest news and updates on the EHR Incentive Programs.

Dallas L Alford IV, CPA is a licensed Certified Public Accountant in the state of North Carolina and owner of Atlantic Financial Consulting, a consulting firm that provides comprehensive medical billing services, practice management consulting, coding audits, Medicare compliance, Medicare RAC support and other general medical practice consulting services.
To learn more about Atlantic Financial Consulting you may visit their website at http://atlanticfinancial.us or contact Dallas L Alford IV, CPA directly at 1 888-428-2555, Ext. 200.