CMS Issues New Guidance on Multiple Locations and Meaningful Use

If an Eligible Professional (EP), Eligible Hospital, or Critical Access Hospital (CAH) see patients in more than one location they will obviously be using multiple certified EHR technology. So just how should numerators and denominators be calculated for meaningful use objectives and measures? CMS has published new information on this issue in the Medicare EHR Incentive program.

Answer from CMS: EPs, eligible hospitals, and CAHs should look at the measure of each meaningful use objective to determine the appropriate calculation method for individual numerators and denominators. The calculation of the numerator and denominator for each measure is explained in the July 28, 2010 final rule (75 FR 44314).

For meaningful use objectives that require a simple count of actions (e.g., number of permissible prescriptions written, for the objective of “Generate and transmit permissible prescriptions electronically (eRx)”; number of patient requests for an electronic copy of their health information, for the objective of “Provide patients with an electronic copy of their health information”; etc.), EPs, eligible hospitals, and CAHs can add the numerators and denominators calculated by each certified EHR system in order to arrive at an accurate total for the numerator and denominator of the measure.

For meaningful use objectives that require an action to be taken on behalf of a percentage of “unique patients” (e.g., the objectives of “Record demographics”, “Record vital signs”, etc.), EPs, eligible hospitals, and CAHs may also add the numerators and denominators calculated by each certified EHR system in order to arrive at an accurate total for the numerator and denominator of the measure. Previously CMS had advised providers to reconcile information so that they only reported unique patients. However, because it is not possible for providers to increase their overall percentage of actions taken by adding numerators and denominators from multiple systems, we now permit simple addition for all meaningful use objectives.

Please keep in mind that patients whose records are not maintained in certified EHR technology will need to be added to denominators whenever applicable in order to provide accurate numbers.

To report clinical quality measures, EPs who practice in multiple locations that are equipped with certified EHR technology should generate a report from each of those certified EHR systems and then add the numerators, denominators, and exclusions from each generated report in order to arrive at a number that reflects the total data output for patient encounters at those locations. To report clinical quality measures, eligible hospitals and CAHs that have multiple systems should generate a report from each of those certified EHR systems and then add the numerators, denominators, and exclusions from each generated report in order to arrive at a number that reflects the total data output for patient encounters in the relevant departments of the eligible hospital or CAH (e.g., inpatient or emergency department (POS 21 or 23)).

Check out all of the CMS Frequently Asked Questions on their new website.

List of Meaningful Use Stage 1 Objectives for Eligible Professionals.
List of Meaningful Use Stage 1 Objectives for Eligible Hospitals.