Health Information Management

CMS releases new and updated FAQs for the EHR Incentive Programs

HIM-HIPAA Insider, September 9, 2013

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by Jaclyn Fitzgerald, Online editor 


CMS recently released four new and five updated FAQs for the Medicare and Medicaid EHR Incentive Programs.

The new FAQs include guidance on the meaningful use stage two transitions of care and referrals objective. CMS suggests three approaches for meeting the second measure in the electronic transmission requirement for 10% of the summary care records provided for transitions of care and referrals. The first two approaches involve eligible providers (EP), eligible hospitals, and critical access hospitals (CAH) using Certified EHR Technology (CEHRT) to electronically submit summary of care records for transitions and referrals. The third involves using CEHRT to create summary care records. Regardless of the method, a transmission will only count if received by a provider to whom the patient has been referred or transferred. Read the complete FAQ.

Another new FAQ states that the job title of medical assistant is not necessary to use the computerized provider order entry function of CHERT if the individual is an appropriately credentialed medical assistant and performs services similar to that of a medical assistant. EPs are responsible for making this determination within their organizations. Read the complete FAQ.

Another FAQ provides guidance on attestation for EPs, eligible hospitals, and CAHs that are transitioning from a 2011 edition to 2014 edition CEHRT during the 2013 program year. In this instance, menu objective and quality measure data from both systems should be combined and reconciliation of the count of unique patients is not necessary. Data collected from the CEHRT used for the majority of the year should be reported if the menu objectives and/or quality measures are changed because of the CEHRT transition. Read the complete FAQ.

CMS also addresses inaccurate calculations of Denominator two for measure CMS64v2. Omitting the “OR” operator in the Risk Assessment Logic between count >= 3 and count = 2 could result in the exclusion of cases from this denominator, especially when a patient’s Framingham Risk Score is not recorded. CMS recommends that EPs record a patient’s Framingham Risk Score in accordance with HHS’ Third Report of the National Cholesterol Education Program, available at http://www.nhlbi.nih.gov/guidelines/cholesterol/atp3full.pdf. The 2014 update will include a  correction of this measure. Read the complete FAQ.


The updated FAQs include:

  1. How does a provider attest to a meaningful use objective (e.g., the “transitions of care,” “view/download patient data,” and public health objectives) where the provider electronically transmits data using technical capabilities provided by a health information exchange? Read the answer.
  2. 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.
  3. When new versions of CQM specifications are released by CMS, do developers of EHR technology need to seek retesting/recertification of their certified complete EHR or certified EHR module in order to keep its certification valid? Read the answer.
  4. If EHR technology “Product A” is already certified to the December 2012 CQM specifications, can it be updated to include CMS updated June 2013 specifications without seeking retesting/recertification? Read the answer.
  5. If EHR technology is not yet certified to CQM criteria (45 CFR 170.314(c)(1) through (3)), can the EHR technology be tested and certified to only the newest available version of the CQM specifications or must it be tested and certified to the December 2012 specifications (first or as well)? Read the answer.
Learn more about the Medicare and Medicaid EHR Incentive Programs.



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