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CMS Clarifies Meaningful Use Reporting Specifics

Eligible hospitals (EHs) and eligible professionals (EPs) now have clarification from the Centers for Medicare & Medicaid Services (CMS) regarding select measures in the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs.

In three recently published lists of frequently asked questions, CMS provides guidance on how EHs and EPs can attest to the health information exchange and patient electronic access measures, as well as objectives that require patient action. These measures are included in the recent final rule modifying meaningful use requirements for 2015 to 2017.

CMS clarified that EHs and EPs may count transitions of care or referrals involving third-party organizations for the health information exchange measure, as long as the third-party organization plays a role in determining the next provider of care and delivers the summary of care document. Further, the provider must create and transmit the summary of care document to the third-party organization using certified EHR technology (CEHRT) for the instance to count toward meaningful use of CEHRT.

Additionally, CMS clarified that multiple EHs or EPs may count a patient accessing a shared online portal toward their meaningful use metrics, as long as each individual provider has contributed information to the portal. The information that the patient views does not need to be the information contributed by the EH or EP.

Last, CMS declared that the transitive property applies to measures that involve patient action in a group practice setting. Specifically, any EP at the group practice that has seen the patient may count these patient actions toward meaningful use objectives:

  • sends an electronic message
  • views, downloads, or transmits to a third party health information made available online
  • uses patient-specific education resources provided electronically

Contact Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Matt Buechner is the policy and advocacy associate for America's Essential Hospitals.

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