Home > EHR, meaningful use, Medicare > 2011 ACR Informatics Summit Questions: Part 1

2011 ACR Informatics Summit Questions: Part 1

At the recent ACR Informatics Summit, I received several questions regarding the Medicare/Medicaid EHR Incentive Program, or “meaningful use” (MU). Some of the questions were about compliance with specific functional measures, which are always inadvisable to discuss without the regulations and guidance in hand; while others were about ACR’s advocacy on MU or how the agencies involved view certain concepts. I thought it might be useful to dive into some of the more memorable questions in a series of entries over the next couple of weeks.

Question (paraphrased): How does CMS view the exclusions from individual MU measures?  Will we get dinged later for invoking some of these exclusions?

Answer: When I thought about this after the event, I realized there is a four-part answer to this question:

  • Eligible professional s (EPs) who meet the exclusions for specific functional measures are not doing anything wrong or negative if they invoke the exclusion. The exclusions were designed by CMS because the agency had to provide flexibility in order to allow EPs with varying scopes of practice to comply with a single set of requirements.
  • CMS is tracking the exclusions — not to penalize the EPs who invoked them, but rather to see which functional measures are in need of modification or removal. If a given functional measure shows a high percentage of EPs invoking the exclusion, something is wrong with the measure itself.
  • CMS is concerned with an unintentional loophole in the regulations that allows EPs to lower the number of menu set functional measures they need for compliance by invoking menu set measure exclusions AND then still reporting the excluded menu set functional measures.  This scenario was discussed by CMS staff during a recent HIT Policy Committee meeting.
  • I have heard on a few separate occasions from (nongovernmental) primary care folks who thought the exclusions made MU compliance “easier” for specialists. This view is misinformed and is not shared by the agencies.
Categories: EHR, meaningful use, Medicare
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  1. November 16, 2011 at 1:53 pm

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