CMS answers more questions about EHR incentive programs

The Centers for Medicare & Medicaid Services has released eight new answers to frequently asked questions (FAQs) to keep providers informed about the Medicare and Medicaid electronic health record incentive programs.

A few of the questions answered include:

"Does a provider have to record all clinical data in their certified EHR technology in order to accurately report complete CQM data for the Medicare and Medicaid EHR Incentive Programs?"

Answer: According to CMS, providers are encouraged to capture complete clinical data in their EHRs, but CMS recognizes that many providers can't do that yet, so they don't have to record all of the data.

"Do providers have to contribute a minimum dollar amount toward their certified EHR technology for the Medicare and Medicaid EHR Incentive Programs?"

Answer: Since the incentives are not designed to reimburse providers for the costs of EHRs, providers don't have to contribute a minimum dollar amount toward the EHR they use. However, providers still need to comply with the Stark law, which requires, among other things, that physicians who receive a donation of EHR items and services from a "DHS entity" [typically a hospital] to pay 15 percent of the donor's cost for the items and services.

"Can two separate practices with two different TINs purchase a single certified EHR system and share it in order to participate in the Medicare and Medicaid EHR Incentive Programs?"

Answer: If a hospital uses EHRs in more than one location or with multiple systems, it should generate a report from each EHR system and then add the numerators, denominators, and exclusions from each generated report in order to arrive at a number that reflects the total data output for patient encounters.

In all, CMS has posted more than 230 new or updated Answers to FAQs regarding the EHR incentive programs.

To learn more:
- here are all eight of the updated questions
- check out the entire list of FAQs (.pdf)

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