Meaningful Use FAQs

Q1: If eligible professionals (EPs) are unable to meet the measure of a Meaningful Use objective because it is outside the scope of their practice, will they be excluded from meeting the measure of that objective under the Medicare and Medicaid Electronic Health Record (EHR) Incentive Payment Programs? Answer

Q2: To meet the Meaningful Use objective, "capability to exchange key clinical information," for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Payment Programs, can different providers of care (e.g., physicians, hospitals, etc.) share EHR technology and successfully meet this objective? Answer

Q3: If my certified EHR technology has the capability to submit information to an immunization registry using the HL7 2.3.1 standard, but the immunization registry accepts information formatted in the HL7 2.5.1 or some other standard, will I qualify for an exclusion because the immunization registry does not have the capacity to receive the information electronically? What if the immunization registry has a waiting list or is unable to test for other reasons but can accept information formatted in HL7 2.3.1, is that still a valid exclusion? Answer

Q4: What is the reporting period for EPs participating in the EHR Incentive Payment program? Answer

Q5: I am an EP for whom none of the core, alternate core, or additional clinical quality measures adopted for the Medicare and Medicaid Electronic Health Record (EHR) incentive programs applies. Am I exempt from reporting on all clinical quality measures? Answer

Q6: Does the person who completed the registration for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Payment Programs need to be the same person who completes the attestation? Answer

Q7: How do I know if my EHR system is certified? How can I get my EHR system certified? Answer

Q8: The meaningful use standards for the Medicare and Medicaid EHR Incentive Payment Programs require interoperability. Who will pay for ensuring connectivity between physician practices and hospitals? Will there be federal guidance, or will this be discussed at a local/community level? Answer

Q9: For the Medicare and Medicaid EHR Incentive Payment Programs, what changes were made to Stage 1 objectives and policies for 2013? Answer

A1: Some Meaningful Use objectives provide exclusions and others do not. Exclusions are available only when our regulations specifically provide for an exclusion. EPs may be excluded from meeting an objective if they meet the circumstances of the exclusion. If an EP is unable to meet a Meaningful Use objective for which no exclusion is available, then that EP would not be able to successfully demonstrate Meaningful Use and would not receive incentive payments under the Medicare and Medicaid EHR Incentive Payment Programs. Back to top

A2: With the 2013 Stage 1 changes, this objective is no longer required. However, in order to meet this objective, clinical information must be sent between different legal entities with distinct certified EHR technology and not between organizations that share a certified EHR technology or organizations that are part of the same legal entity. This is because no actual exchange of clinical information would take place in these latter instances. Distinct certified EHR technologies are those that can achieve certification and operate independently of other certified EHR technologies. Back to top

A3: If the immunization registry does not accept information in the standard to which your EHR technology has been certified, (that is, if your EHR is certified to the HL7 2.3.1 standard, and the immunization registry accepts only HL7 2.5.1, or vice versa) and if the immunization registry is the only immunization registry to which you can submit such information, then you can claim an exclusion objective because the immunization registry does not have the capacity to receive the information electronically. The capacity of the immunization registry is determined by the ability of the immunization registry to test with an individual EP or eligible hospital (EH). An immunization registry may have the capacity to accept immunization data from another EP or hospital, but if for any reason (waiting list, on-boarding process, other requirements, etc) the registry cannot test with a specific EP or hospital, that EP or hospital claim an exclusion. It is the responsibility of the EP or hospital to document the justification for their exclusion (including making clear that the immunization registry in question is the only one it can submit information to). If the immunization registry, due to State law or policy, would not accept immunization data from you (e.g., not a lifespan registry, etc), you can also claim the exclusion for this objective. Please note that this information applies in principle to all of the Stage 1 public health meaningful use measures (syndromic surveillance and reportable lab conditions). Back to top

A4: For demonstrating meaningful use through both the Medicare and Medicaid EHR Incentive Payment programs, the EHR reporting period for an EP's first year is any continuous 90-day period within the calendar year. In subsequent years, the EHR reporting period for EPs is the entire calendar year. Under the Medicaid program, there is also an incentive for the adoption, implementation, or upgrade of certified EHR technology, which does not have a reporting period. Back to top

A5: In the event that none of the 44 clinical quality measures included in Table 6 of our final rule applies to an EP's patient population, the EP is still required to report a zero for the denominators for all six of the core and alternate core clinical quality measures. The EP is also required to report on at least three of the additional clinical quality measures of their choosing from Table 6 of the final rule (other than the six core/alternative core measures). If the EP reports zero values for these three additional, menu-set clinical quality measures, then for the remaining menu-set clinical quality measures, the EP will have to attest that all the other menu-set quality measures calculated by the certified EHR technology have a value of zero in the denominator. In other words, the EP is required to try to find at least three measures in the menu set for which the denominator is other than zero. If this is not possible, the EP must still choose three menu-set measures on which to report.

When EPs report zero denominators for some or all measures, an attestation must accompany such reporting. The attestation should clearly state that all of the other menu-set measures calculated by the certified EHR technology have a value of zero in the denominator. A zero report in the menu set is not sufficient without such accompanying attestation. Refer to page 44410 of the preamble to the final rule. Back to top

A6: No. For Medicare providers, Centers for Medicare & Medicaid Services (CMS) has determined that if there are multiple users approved to work on behalf of an eligible professional (EP), any of those authorized users can update the EP's registration or attestation. In addition, EPs can log in and update the information personally. For Medicaid, each state determines whether or not they allow authorized third parties to attest on behalf of EPs. Back to top

A7: The Medicare and Medicaid EHR Incentive Payment Programs require the use of certified EHR technology as established by a new set of standards and certification criteria. Existing EHR technology needs to be certified by the Office of the National Coordinator for Health Information Technology (ONC)-Authorized Testing and Certification Body (ATCB) to meet these new criteria in order to qualify for incentive payments. The Certified Health IT Product List (CHPL) is available at http://www.healthit.hhs.gov/CHPL. This is a complete list of EHRs and EHR modules that have been certified for the purpose of this program. Back to top

New certification bodies have been established to test and certify EHR technology. Vendors can submit their EHR products to the certifying bodies to be tested and certified. Hospitals and practices who have developed their own EHR systems or products can also seek to have their existing systems or products tested and certified. Complete EHR systems may be certified, as well as EHR modules that meet at least one of the certification criteria. Once a product is certified, the name of the product will be published on the ONC website at http://www.healthit.hhs.gov/CHPL. Back to top

A8: The ONC has awarded funds to 56 states, eligible territories, and qualified State Designated Entities (SDEs) under the Health Information Exchange Cooperative Agreement Program to help fund efforts to rapidly build capacity for exchanging health information across health care systems within and between states. This exchange will play a critical role in improving the exchange capacity of doctors and hospitals to help them meet interoperability requirements, which will be part of meaningful use. More information on the ONC's Health Information Exchange grantees is available at: http://healthit.hhs.gov/. Back to top

A9:The final rule for August 23, 2012, includes some changes to the Stage 1 meaningful use objectives, measures, and exclusions for eligible professionals, eligible hospitals, and critical access hospitals. Some of these changes will take effect as early as October 1, 2012, for eligible hospitals and critical access hospitals, or January 1, 2013, for eligible professionals. Other Stage 1 changes will not take effect until the 2014 fiscal or calendar year, and will be optional in 2013. Back to top

Changes to specific objectives, measures, and policies are listed here.