Archive for May, 2015

ACR Submits Comments on CMS’ Stage 3 Meaningful Use Proposed Rule

May 28, 2015 2 comments

The American College of Radiology (ACR) formally submitted comments to the Centers for Medicare and Medicaid Services (CMS) on May 28 addressing the agency’s proposed rule to implement Stage 3 of the EHR Incentive Program. The ACR’s comments are accessible here.

The ACR also plans to comment next month on CMS’ proposed rule to reform EHR Incentive Program participation requirements in 2015 through 2017. If interested in providing feedback on that rulemaking, please contact Michael Peters, ACR Director of Regulatory and Legislative Affairs, at 202-223-1670 or

Categories: EHR, meaningful use, Medicare

CMS Staff Clarify Scope of the Meaningful Use ‘Medications Reconciliation’ Denominator

The Centers for Medicare and Medicaid Services (CMS) staff informed the American College of Radiology (ACR) that the denominator for the current “medications reconciliation” Stage 1 and Stage 2 Meaningful Use measure can be limited to the subset of patients that comprise the physician’s “seen” definition.


In the explanatory preamble of CMS’ September 2012 Stage 2 MU rule, the agency clarified: “for an EP who is on the receiving end of a transition of care or referral, (currently used for the medication reconciliation objective and measure), the denominator includes first encounters with a new patient and encounters with existing patients where a summary of care record (of any type) is provided to the receiving provider.” This was a major change from the 2010 Stage 1 MU rule which clearly distinguished the term “transitions of care” from “referrals” in which the referring provider maintained management of the patient. Ultimately, the 2012 clarification meant that referral-based care was to be included in the “medications reconciliation” objective/measure moving forward.

Many MU participating radiologists have used the “seen patients” flexibility to appropriately reduce their denominators for applicable objectives to more manageable numbers. Previously, “medications reconciliation” was not thought of as being an applicable objective because the denominator of “received transitions of care” does not refer to “patients seen by the EP.” So, whereas a radiologist could have been meeting other percentage-based MU measures on a smaller subset of their overall patient volume, they would have needed to use their full patient volume for the “medications reconciliation” measure under the 2012 clarification.

However, CMS staff recently indicated to ACR that the word “encounters” in the 2012 clarification (“…first encounters with a new patient and encounters with existing…”) could be interpreted the same as the physician’s defined “seen” patients. This view would limit the application of the “received transitions of care” denominator to the smaller subset of “seen” patients used in most of the physician’s other applicable MU objectives. Moreover, if a physician could somehow define their “seen” patients as not including services that meet the 2012 “received transitions of care” clarification, they could once again qualify for the exclusion from the “medications reconciliation” objective.

Categories: EHR, meaningful use, Medicare