The Centers for Medicare and Medicaid Services (CMS) recognize that “not every meaningful use measure applies to every provider,” and some of the original policy architects have noted that the criteria were written with primary care more in mind than specialties. To help specialists understand and employ EHR Incentive Program exemptions to those primary care-centric rules, CMS compiled new meaningful use guidance in the form of a tipsheet.
The initiative seems to confirm CMS is coming around to the idea that meaningful use objectives are devised with a sort of asymmetrical/ implementation in mind. In other words, primary care physicians will go online first, while specialists will lag behind.
Tipsheet topics include:
- Reporting measure exclusions: While all providers must report on clinical quality measures, specialists are encouraged to pick and choose only the ones relevant to their practices. And if none are applicable, specialists can simply generate a value of zero in their EHR attestation.
- Using other providers’ data: CMS understands that most specialists don’t interact with patients in the same way general practitioners do, and for that reason allow health information exchanges to assist in EHR reporting. It doesn’t matter where the information comes from (neither the HIE nor the referring provider has to have certified EHR technology), as long as certified EHR technology is used to record and store it.
- Determining office visits for applicable measures: CMS defines office visits as concurrent care/transfer of care visits, consultant visits, or Prolonged Physician Service without Direct Patient Contact (CMS’s long name for telehealth). If specialists don’t fall under any of those formats, they’re free to claim exemption. Alternatively, they may count the summary provided by other EP(s) who saw the patient as their own, granted the EPs share an EHR and generate a single clinical summary at the end of the visit.
- Applying for a hardship exemption: Although some specialists can apply for hardship exemptions for meaningful use objectives with which they simply can’t comply, information on how to do that isn’t available yet. When it does, specialists who lack face-to-face or telemedicine interaction with patients – or can’t access Certified EHR Technology for 50% or more of patient encounters – will be eligible for the exemption.
The tipsheet also includes links to resources like specification sheets, introductions to Medicare and Medicaid, and a meaningful use calculator to help specialists further navigate the EHR incentive programs. For further information, consult SearchHealthIT’s guide for specialists attempting to tackle meaningful use compliance.