MDNews - Central New York

May/June 2014

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T HERE HAVE BEEN several unfore- seen obstacles so far this year for eligible professionals (EPs) seeking meaningful use. Delays in obtaining the 2014 certified ver- sion of electronic health record (EHR) software from vendors have gotten the most attention. The work effort involved in implementing the new software ver- sions and addressing new Stage 2 rules has recently prompted the Centers for Medicare & Medicaid Services (CMS) to postpone reimbursement penalties, via a hardship exemption process, for not attaining meaningful use. Hurdles that have drawn less attention, how- ever, involve physicians who practice at mu lt iple locat ions, where t hey may have little inf luence in business decision-making. Physicians practicing in multiple locations face two situations in which CMS rules need to be applied. One involves what is referred to as "the 50 percent r ule" which states that 50 percent of an EP's total encounters must be at a location where certified technology is available. They must base all meaningful use measures only on the encounters that occur at those locations. There is a hardship exemption that would eliminate the reimbursement penalty for EPs who practice medicine in locations where they are unable to control the availability of certified EHR technology if those locations contribute more than 50 percent of their outpatient encounters. It should be noted that to be considered "certified," an EHR must be certified at the 2014 level and for the EP's full reporting period. EPs who have 50 percent of their encounters at locations where there is a certified system do not count the data from the noncertified locations in their calculations of meaningful use measures. However, meaningful use measure data from all those loca- tions that have a certified EHR must be included in the measures reported to CMS. The EHR must be certified for the EPs' entire reporting period. If it is not, it is treated as though it were not certified at all. Take the example of a physician who is a partner in a practice with a certified EHR but also works independently at a hospital outpatient clinic and two other private practices. If one of the other private practices does not have a 2014 certified EHR, its encounters can be eliminated from measure calculations. If the hospital Meaningful Use Rules Require Collaboration among Medical Organizations By John Netti Hurdles for Physicians Working in Multiple Locations +++++++++++++++++++++++ + +++ + +++ +++++++++++++++++++++++ MEANINGFUL USE 2 4 | Central New York MD NEWS ■ M D N E W S . CO M

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