CMS Updates 'Meaningful Use' FAQs, Clarifies Participation in Multiple Programs

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The Centers for Medicare & Medicaid Services has updated its frequently asked questions about the Medicare and Medicaid electronic health record incentive programs, adding four new questions to the list.

In one of the new FAQ entries, CMS clarified that eligible professionals can participate in the Physician Quality Reporting System if they also are enrolled to participate in the Medicare Electronic Prescribing Incentive Program or the Medicare or Medicaid incentive programs. However, eligible professionals are not able to receive incentive payments under both the Medicare eRx incentive program and the Medicare meaningful use program in the same year, even though they must report the eRx measures to avoid penalties if they are enrolled in the Medicare meaningful use program, CMS said.

Eligible professionals participating in the Medicaid meaningful use program may also participate in the Medicare eRx program, but cannot also participate in the Medicare meaningful use program.

Also among the new FAQs, CMS said that in most cases, providers are not limited to demonstrating meaningful use of EHR technology in the exact way an EHR system or module was certified.

Demonstrating Meaningful Use.

“As long as an eligible professional or eligible hospital uses the certified Complete EHR or certified EHR Module's capabilities and, where applicable, the associated standard(s) and implementation specifications that correlate with the respective meaningful use objective and measure, they can successfully demonstrate meaningful use even if their exact method differs from the way in which the Complete EHR or EHR Module was tested and certified,” CMS wrote in the FAQ.

CMS noted, though, that certification is intended to ensure that EHR technologies can perform according to the requirements of the meaningful use program. As such, providers should consider whether changes in how they use the products will adversely affect the capabilities of the complete EHRs or modules for which they were certified, “which could ultimately compromise an eligible professional or eligible hospital's ability to successfully demonstrate meaningful use,” according to the FAQ.

CMS also clarified that providers who enter patient information into an EHR at a practice location other than the setting where they saw patients can count those patients in their numerators and denominators for meaningful use measures.

“However, [eligible professionals] should be aware that it is unlikely that they will be able to include such patients in the numerator for the measure of the 'use computerized provider order entry (CPOE)' objective or for the e-prescribing measure,” CMS noted.

The FAQs can be found at,26,1139.