CMS Staff Clarify Scope of the Meaningful Use ‘Medications Reconciliation’ Denominator

In this months post, we take a look at a recent article posted on Radiology and HIT Blog discusses recent clarification .

The Centers for Medicare and Medicaid Services (CMS) staff informed the American College of Radiology (ACR) that the denominator for the current “medications reconciliation” Stage 1 and Stage 2 Meaningful Use measure can be limited to the subset of patients that comprise the physician’s “seen” definition.

In the explanatory preamble of CMS’ September 2012 Stage 2 MU rule, the agency clarified: “for an EP who is on the receiving end of a transition of care or referral, (currently used for the medication reconciliation objective and measure), the denominator includes first encounters with a new patient and encounters with existing patients where a summary of care record (of any type) is provided to the receiving provider.” This was a major change from the 2010 Stage 1 MU rule which clearly distinguished the term “transitions of care” from “referrals” in which the referring provider maintained management of the patient. Ultimately, the 2012 clarification meant that referral-based care was to be included in the “medications reconciliation” objective/measure moving forward.

Many MU participating radiologists have used the “seen patients” flexibility to appropriately reduce their denominators for applicable objectives to more manageable numbers. Previously, “medications reconciliation” was not thought of as being an applicable objective because the denominator of “received transitions of care” does not refer to “patients seen by the EP.” So, whereas a radiologist could have been meeting other percentage-based MU measures on a smaller subset of their overall patient volume, they would have needed to use their full patient volume for the “medications reconciliation” measure under the 2012 clarification.

Read more on the Radiology and HIT Blog.

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2014 CEHRT Hardship Exception Guidance for EPs

In this month’s post, we take a look at the 2014 CEHRT Hardship Exception Guidance for Eligible Professionals (EPs). 

If you are an eligible professional, and you are unable to implement the 2014 Edition of Certified Electronic Health Record (EHR) Technology in time to successfully demonstrate meaningful use for the 2014 reporting year, you may be eligible for a hardship exception from the applicable Medicare payment adjustment.

When do payment adjustments take effect for the 2014 reporting year?

The Medicare EHR Incentive Program payment adjustment is applied in 2016 for the 2014 reporting year for providers who demonstrated meaningful use in a previous year. New participants in the 2014 reporting year can also apply for an exception to the 2015 payment adjustment. CMS is currently accepting hardship exception applications for the 2015 payment adjustment only.

New Participants in 2014

If you are new to the program and intended to demonstrate meaningful use for the first time in 2014, but you are not able to implement 2014 certified EHR technology for the 2014 reporting year, you may apply for a hardship exception for the 2015 payment adjustment.

  • Use the eligible professional hardship exception form for 2015
  • Indicate the reason you are applying for a hardship (select “2014 Vendor Issues”)
  • Submit your application by July 1, 2014

Returning Meaningful Users in 2014

If you successfully demonstrated meaningful use for the 2013 reporting year, you will not be subject to the 2015 payment adjustment. If you are not able to implement 2014 certified EHR technology for a 2014 reporting period, you may apply for a hardship exception for the 2016 payment adjustment.

  • Use the eligible professional hardship exception form for 2016 which will be available after July 1, 2014
  • Indicate the reason you are applying for a hardship (select “2014 Vendor Issues”)
  • Submit your application by July 1, 2015

For more information, please review the 2014 CEHRT Hardship Exception Guidance for Eligible Professionals documentation posted on the CMS website: http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/CEHRT2014_HEGuidance_EPs.pdf

Ready to learn more, buy a book today!

Go to http://www.theMUguide.com to learn more. Buy a book from the official e-store (http://buy.theMUguide.com) or Amazon.com (http://amazon.theMUguide.com).