Home > EHR, meaningful use, Medicare > RBMA, ACR and Other Stakeholders Meet With ONC to Discuss Hospital-Located EPs Without Physical Practice Infrastructures

RBMA, ACR and Other Stakeholders Meet With ONC to Discuss Hospital-Located EPs Without Physical Practice Infrastructures

Yesterday, representatives from the Radiology Business Management Association, Healthcare Billing and Management Association, Medical Group Management Association, and American College of Radiology met with Office of the National Coordinator for HIT staff to discuss considerations and complications related to EHR Incentive Program (“meaningful use”) participation by eligible professionals (EPs) in hospital-located practices that do not have physical infrastructures.

EPs in these practice scenarios rely on the helpfulness of their hospitals, via technology and/or data access, to satisfy the various requirements of the program.  Several hospital-located practices, particularly those in small community hospitals, have encountered barriers in trying to work with hospitals on EP compliance.

The two primary “asks” for the meeting were:

  • Provide information/guidance for hospitals regarding compliance facilitation for EPs who are not technically “hospital-based” but work in, or for, hospitals.
  • Work with CMS to define a future significant hardship exemption option for certain hospital-located EPs who are not adequately enabled by their facilities to participate. Of course, the future significant hardship exemption mechanism is required by statute to have a five-year maximum and an annual application requirement.  It could never be a permanent fix without new legislation.
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Categories: EHR, meaningful use, Medicare

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