FW: New FAQs
MUSE
From: Thomas, Cheyenne A.--IRM (Silva) [mailto:Thom...@inhs.org]
Sent: October-19-10 8:37 AM
To: IRM Internal Meaningful Use Team; mu...@museweb.org
Subject: New FAQs
HI All,
Here are a few new FAQ responses that I thought were relevant. The first is the most important because in the section that I have highlighted, it appears to agree with the ONC stand that each site must have a complete EHR with certified products for each objective, even those that they will be deferring. In light of this answer and that from ONC, it would appear that each site will need to have certified technology available that would constitute a "complete EHR" but would not need to implement use of those areas that would be needed for the deferred objectives. I am also pasting in ONC FAQ #17 on the same subject.
If a provider feeds data from certified electronic health record (EHR) technology to a data warehouse, can the provider report on Meaningful Use objectives and clinical quality measures from the data warehouse?
To be a meaningful EHR user a provider must do two things:
1. Have complete certified EHR technology for all meaningful use objectives either through a complete EHR or a combination of modules; and
2. Meet 20 measures (19 for eligible hospitals and CAHs), including all of the core and five (5) menu-set measures associated with the objectives (unless excluded). Core measures include reporting clinical quality measures.
In meeting those measures providers must use certified EHR technology in the way it was certified to accomplish that objective. However, the ability to have this type of arrangement certified resides with the Office of the National Coordinator of Health Information Technology (ONC). For more information about certification, you can contact ONC directly at onc.cert...@hhs.gov.
ONC FAQ #17:
Question [9-10-017-1]:
Under the Medicare and Medicaid EHR Incentive Programs Final Rule, eligible health care providers are permitted to defer certain meaningful use objectives and measures and still receive an EHR incentive payment. However, it is our understanding that in order for us to have our EHR technology certified, we must implement all of the applicable capabilities specified in the adopted certification criteria regardless of whether we intend to use all of those capabilities to qualify for our EHR incentive payment. Is our understanding correct?
Answer:
Yes, this understanding is correct. The flexibility offered as part of the Medicare and Medicaid EHR Incentive Programs Final Rule is not mirrored in the Initial Set of Standards, Implementation Specifications, and Certification Criteria Final Rule because we believe that it is important to accommodate eligible health care providers’ ability to achieve meaningful use. We recognize that in some circumstances an eligible health care provider may not know which meaningful use measures they will seek to defer until they begin implementation and in others an individual provider (even within a specialty) will want to choose different measures to defer based on their local situation and implementation experience. Thus, in order to possess EHR technology that meets the definition of Certified EHR Technology, it must be tested and certified by an ONC-ATCB to all applicable certification criteria adopted by the Secretary.
Quality Measures Objective (C11):
For eligible hospitals and critical access hospitals (CAHs) under the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs, will the clinical quality measure results be calculated similar to the Reporting Hospital Quality Data for Annual Payment Update (RHQDAPU) program?
No. For all clinical quality measures reported for the Medicare and Medicaid EHR Incentive Programs, the certified EHR must report the numerator, denominator, and exclusion results. Providers will report their aggregate results for clinical quality measures during attestation to CMS or the States.
Education Objective (M7):
To meet the meaningful use objective "use certified EHR technology to identify patient-specific resources and provide those resources to the patient" for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs, does the certified EHR have to generate the education resources or can the EHR simply alert the provider of available resources?
In the patient-specific education resources objective, education resources or materials do not have to be stored within or generated by the certified EHR. However, the provider should utilize certified EHR technology in a manner where the technology suggests patient-specific educational resources based on the information stored in the certified EHR technology. The provider can make a final decision on whether the education resource is useful and relevant to a specific patient.
Demographics Objective (C4):
For the meaningful use objective of "record demographics" for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Program, what documentation is required when recording the preliminary cause of death in the event of mortality?
Eligible hospitals and critical access hospitals (CAHs) must record in the patient's EHR the clinical impression and preliminary assessment of the cause of death. No further documentation is required. This measure does not require the cause of death to be updated if the case is referred to the Department of Health or coroner's office.
Thanks,
Cheyenne Thomas
INHS/IRM
Manager, Regional Accounts
509-232-8180
thom...@inhs.org
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