CMS answers toughest meaningful use questions

You now have official answers from CMS on some of the trickiest meaningful use questions around, including just how much clinical data you need to record and how to record measures for providers who use electronic health records (EHRs) in multiple locations.

The answers, some complete, some barely helpful, are now on CMS’s frequently asked questions (FAQ) page at https://questions.cms.hhs.gov/.

Here’s a rundown on the latest ones for meaningful use:

• Does all clinical data have to be recorded to EHR? In other words, can you still keep some patient encounter information on paper – something of a gray area until now. The answer is, to meet the clinical quality measures (CQMs) required under meaningful use, you do not have to record all clinical data to your EHR. “We recognize that … many providers are not able to capture all data at this time,” CMS acknowledges. “Although we encourage providers to capture complete clinical data in order to provide the best care possible for their patients, for the purpose of reporting [CQM] data, CMS does not require providers to record all clinical data in their certified EHR technology at this time.” When attesting, you should report numerators and denominators based on what is recorded in your EHR, CMS says.
• How providers who use EHR in multiple locations report meaningful use data? Basically, for measures that need a simple count of actions (such as number of prescriptions written for the e-prescribing measure), just add up the numerators and denominators across locations, CMS says. For measures that require more complex data, such as a percentage of “unique patients,” you will need to ensure each unique patient in each location is counted only once for each measure, CMS says. Patients not captured by EHR but still seen by a provider must be counted toward the denominator for the reporting to be accurate.
• Where do I find a list of health agencies and immunization registries to submit data to? You need to meet either the syndromic surveillance measure or the immunization registry submission measure (both menu, but you need to meet one of them) to earn your incentive cash. Problem is, very few states have health agencies or immunization registries that are ready to receive submissions. CMS’s answer: “Please contact your local or state public health agencies and immunization registries.” You can probably mark this one under “barely helpful.”

Remember: Check out our series of articles on meeting the 15 core meaningful use measures, which appeared in Part B News over the last few months. Look for a compiled package of these articles in the near future.