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CMS answers more EHR questions

CMS released a new batch of FAQs Friday regarding Electronic Health Record (EHR) Incentive Programs, which could make your switch to EHR seem less ominous. Some of CMS' responses include clarification on what a "reasonable cost" is under the new program, determining how hospital-based status is determined for eligible professionals, discussing whether large practices will be able to register all eligible professionals at once and more.

Here are a couple of the new questions:

For the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs, does an eligible hospital have to count patients admitted to both the inpatient and emergency departments in the denominator of meaningful use measures, or can they count only emergency department patients?

For the hospital meaningful use objectives, the denominator is all unique patients admitted to an inpatient (POS 21) or emergency department (POS 23), which means all patients admitted to an inpatient department (POS 21) and all patients admitted to an emergency department (POS 23). If the eligible hospital elects to use the alternate method for calculating emergency department patients, as detailed in FAQ #10126), the denominator is all unique patients admitted to an inpatient department (POS 21) and all patients that initially present to the emergency department and are treated in the emergency department's observation unit or otherwise receive observation services, which includes patients who receive observation services under both POS 22 and POS 23. Patients admitted to the inpatient department must be included in the denominator of all applicable measures.

If a hospital is eligible to participate in both the Medicare and Medicaid EHR Incentive Programs, how should they register?

If a hospital meets all of the following qualifications, it is dually-eligible for the Medicare and Medicaid EHR Incentive Programs:

  • It is a subsection(d) hospital in the 50 U.S. States or the District of Columbia, or you are a Critical Access Hospital (CAH), and
  • It has a CMS Certification Number ending in 0001-0879 or 1300-1399, and
  • It has 10% of patient volume derived from Medicaid encounters.

Any hospitals that meet these three qualifications, must register for "Both Medicare & Medicaid" when registering for the programs.

Take a look and if you have a question they didn't answer, let us know!

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