CMS Releases New Meaningful Use FAQ for EPs using Hospital EHRs
CMS released a new FAQ on June 27 to help clarify to what extent an eligible professional (EP) can use a hospital EHR to meet Meaningful Use objectives and measures. The FAQ makes it clear that an EP can use both a certified ambulatory EHR and a certified inpatient EHR to demonstrate Meaningful Use. Therefore, provided that the ambulatory EHR is used to meet those measures for which the inpatient EHR is not designed for (e.g., EP clinical quality measures, e-prescribing), a physician can use both to successfully attest.
ONC specifically lists the following measures as being flexible enough to use either inpatient or ambulatory EHRs:
- 170.304(a) which is the same as 170.306(a); (CPOE)
- 170.304(e) which is the same as 170.306(c); (clinical decision support rule)
- 170.306(b) which is more comprehensive than 170.304(c); (demographics recorded as structured data)
- 170.306(d) which is more comprehensive than 170.304(f); (electronic copy of health information) and
- 170.306(f) which is more comprehensive than 170.304(i). (exchange key clinical information)
This and other CMS FAQs can be found on the CMS FAQ page and the ONC FAQs are available on the ONC Regulations FAQ page. As a reminder, Tuesday, July 3, is the last day for hospitals and critical access hospitals to begin their 90-day reporting period for the fiscal year.
CMS FAQ 6421
Question: Can an EP use EHR technology certified for an inpatient setting to meet a meaningful use objective and measure?
Answer: Yes. For objectives and measures where the capabilities and standards of EHR technology designed and certified for an inpatient setting are equivalent to or require more information than EHR technology designed and certified for an ambulatory setting, an EP can use the EHR technology designed and certified for an inpatient setting to meet an objective and measure. There are some EP objectives, however, that have no corollary on the inpatient side. As a result, an EP must possess Certified EHR Technology designed for an ambulatory setting for such objectives. Please reference ONC FAQ 12-10-021-1 and 9-10-017-2 and CMS FAQ 10162 for discussions on what it means to possess Certified EHR Technology, ONC FAQ 6-12-025-1 for a list of affected capabilities and standards, and how that relates to the exclusion and deferral options of meaningful use.
