Home > EHR, meaningful use, Medicare > CMS Implements ACR Recommendation: Addresses Stage 2 Meaningful Use Compliance Barrier

CMS Implements ACR Recommendation: Addresses Stage 2 Meaningful Use Compliance Barrier

The Centers for Medicare and Medicaid Services (CMS) recently released new guidance to allow physicians without office visits to obtain an exclusion from the Stage 2 Meaningful Use (MU) “electronic notes” menu objective. The American College of Radiology has been advocating for this change since the September 2012 publication of the Stage 2 MU final rule.

Prior to the guidance, compliance with Stage 2 MU was effectively impossible for physicians without office visits. The reason was that office visits were used in the denominator for the electronic notes measure, yet CMS did not provide a corresponding exclusion for physicians with zero office visits during the reporting period. As most physicians without office visits would also tend to be excluded from 3-5 menu objectives in Stage 2 MU—and menu exclusions no longer reduce the total number of menu objectives participants must report (as of 2014)—those physicians would be required by default to “choose” the electronic notes menu objective.

The above circumstances created a perfect storm for failure… Zero denominators are not allowed for the MU objectives, so participants without office visits were either doomed to fail the electronic notes objective—and therefore fail MU altogether—or had to define their non-visit professional services as “office visits” to generate some kind of a denominator. Doing the latter also meant those participants could not leverage the “no office visits” exclusion for various other Stage 2 MU objectives, thereby making MU even more burdensome.

While it took time due to staff changes and other challenges, CMS should be applauded for taking the necessary steps to correct an administrative oversight that, from their perspective, impacted only a small minority of MU participants (i.e., those without office visits who made it to Stage 2). Moving forward, however, it would be better for all MU objectives to have qualitative, scope of practice-based exclusions so that nuances and seemingly minor oversights do not snowball into major compliance barriers.

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Categories: EHR, meaningful use, Medicare
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