CMS Adds 3 New FAQs on Electronic Health Record Incentive Programs

The Centers for Medicare & Medicaid Services (CMS) has added three new FAQs related to the Medicare and Medicaid electronic health record (EHR) incentive programs.

The questions — and the answers provided by CMS — are as follows:

Q: For the certification criteria that providers must have in place to meet the Clinical Decision Support (CDS) objective, what type of interventions must the EHR technology trigger to meet the criteria? For this and for the Eligible Provider and Eligible Hospital Core Measures related to the Objective "use clinical decision support to improve performance on high-priority health conditions," are "pop-up" alerts the only type of intervention that a provider can use to meet the CDS objective?

CMS: The intention of the CDS intervention certification requirement is to ensure certified EHR technology helps providers make timely and informed decisions. The certification requirement that CDS interventions be 'triggered' means that a CDS intervention – which may come in many forms other than "pop-ups" – be based on relevant, timely patient and care process information and that it may appear in 'real time' when it is most relevant to improve care provision.

CDS is not simply an alert, notification, or explicit care suggestion. Providers can meet the objective by using other kinds of CDS, including, but not limited to clinical guidelines; condition-specific order sets; focused patient data reports and summaries; documentation templates; diagnostic support; and contextually relevant reference information. In addition, CDS interventions are not only for doctors or nurses, but also for support staff, patients, and other caregivers, and may be delivered outside of the examination room or treatment setting.

For more information on Clinical Decision Support, review the eligible professional and eligible hospital specification sheets, and the Clinical Decision Support tipsheet.

Q: I am an eligible professional. What should I do if my patients don't have broadband access?

CMS: Some meaningful use objectives require broadband access. The infrastructure required for the Secure Electronic Messaging objective is similar to the infrastructure required for the Patient Electronic Access objective's successful usage of an online patient portal, as required in the second measure.

Therefore, CMS finalized an exclusion for those two requirements:

An eligible professional that conducts 50 percent or more of his or her patient encounters in a county that does not have 50 percent or more of its housing units with 3Mbps broadband availability, according to the latest information available from the FCC, on the first day of the EHR reporting period may exclude the second measure of the Patient Electronic Access objective and the Secure Electronic Messaging objective.
The FCC's National Broadband Map allows eligible professionals to search, analyze, and map broadband availability in their area: www.broadbandmap.gov.

Q: In the inpatient setting, when providing patient data to satisfy the Summary of Care and View Online, Download, and Transmit objectives, does a hospital have to provide two different documents for patients and providers?

CMS: Eligible hospitals may create one consolidated document for the download requirement of the View Online, Download, and Transmit objective and the Summary of Care objective, as long as it:

  • Has the required fields in it for both objectives
  • Meets the standards for structured data for both objectives

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