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Even more information for the EP who works in multiple locations

on Wed, 02/20/2013 - 3:35am

We have discussed previously the specifics of eligibility for eligible professionals who work at multiple locations ("The 50% rule: what it means for behavioral health EPs" and "More Information for Multiple Location EPs"), but there are more questions when it comes to those EPs meeting the measures of meaningful use.
We have an EP in a full year reporting period (Jan. 1- Dec. 31) who practices at two locations. One of the locations had a certified EHR beginning Jan. 1 while the other implements April 1. Would you limit the measures to the encounters that occur at the location equipped with certified EHR at the beginning of the period, or include the encounters for both locations?

We were under the assumption we would aggregate measures for both locations since they both had EHR for more than half of the reporting period. However, it does not appear one of the locations would meet the term "equipped": "A practice is equipped if certified EHR technology is available at the beginning of the EHR reporting period for a given geographic location." (Federal Register July 28, 2010, Final Rules Part II, page 44329) The EP meets the 50% eligibility for the locaton where EHR was available at the beginning of the period.

In addition, could you address the aggregation of Menu Measures where multiple practices did not choose to either report on the same measures or have the same response? For example, one organization may be exempt from the Public Health Immunization Registry while the other is able to perform the test. How do you address this when your only option is to select a disagreeable measure in the case of not having enough other Menu Measure options between the two reports (some organizations only report on exactly five)?

The situation where EPs work in multiple locations can be quite confusing. The best place to get the answers for your questions is in the FAQs from CMS.
This FAQ addresses your question about which encounters to include when the two agencies implemented a certified EHR at separate times during the calendar year. The first thing the FAQ points out is, it depends on the measure. Some measures look at all encounters regardless of whether or not they are kept in an certified EHR.
Based on this statement in the FAQ, I would agree that you are correct on this point: “For objectives that require a simple count of actions (e.g., number of permissible prescriptions written, for the objective of "Generate and transmit permissible prescriptions electronically (eRx)"; number of patient requests for an electronic copy of their health information, for the objective of "Provide patients with an electronic copy of their health information"; etc.), EPs, eligible hospitals, and CAHs can add the numerators and denominators calculated by each certified EHR system in order to arrive at an accurate total for the numerator and denominator of the measure.”

For your question about the EP who captures data for different Menu Measures in the different location, this FAQ addresses that specific issue:
“The attestation system only allows the selection of 5 menu objectives. If an EP practices in multiple locations that choose to implement the same menu objectives, the EP should combine the data for menu objectives for attestation. For menu objectives that are not shared across multiple locations, the EP should attest to the menu objectives implemented at the location where they have the greatest number of their patient encounters”

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