The Centers for Medicare & Medicaid Services (CMS) released new and updated frequently asked questions (FAQs) for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. The new FAQs clarify how providers can calculate the patient electronic access objective. CMS states that hospitals may include in the numerator patients who accessed their health information online prior to being discharged from the hospital.

The updated FAQs also include information on which transitions of care count toward the summary of care objective. CMS states that transitions must take place between providers with different billing identities. Another updated FAQ includes information on the documentation providers should maintain in the event of an audit of their adopt, implement, or upgrade (AIU) attestation for the Medicaid EHR Incentive Program.

Please contact Shahid Zaman, JD, policy analyst, at or 202.585.0124 with questions.