Scope of Practice

Q and A: Eligible Professionals and Core Objectives, Part 2 (Post 3 of 5)

Because most CMAs (AAMA) work under the direct supervision of “eligible professionals” (as defined in the rules of the Centers for Medicare and Medicaid Services [CMS]), this post focuses on some common questions surrounding the provisions of the Medicare and Medicaid Electronic Health Records (EHR) Incentive Program that are applicable to eligible professionals, not those provisions that are applicable to “eligible hospitals” and “critical access hospitals.”

Q: What Core Objective pertains to the permissibility of CMAs (AAMA) entering orders into the EHR?

A: The relevant Core Objective under Stage 1 of the Incentive Program is titled “CPOE for Medication Orders.” The Stage 2 Core Objective is “CPOE for Medication, Laboratory, and Radiology Orders.”

Q: What does “CPOE” stand for?

A: CPOE stands for “computerized provider order entry.” CPOE is defined as follows: “A provider’s use of computer assistance to directly enter medical orders (for example, medications, consultations with other providers, laboratory services, imaging studies, and other auxiliary services) from a computer or mobile device.”

Q: What are the measures for these Core Objectives in Stages 1 and 2?

A: For Stage 1, the measure is as follows: “More than 30 percent of all unique patients with at least one medication in their medication list seen by the eligible professional (EP) have at least one medication order entered using CPOE.” The Stage 2 measure is more expansive: “More than 60 percent of medication, 30 percent of laboratory, and 30 percent of radiology orders created by the EP during the EHR reporting period are recorded using CPOE.”

Q: Are there exclusions for these measures?

A: Yes. The Stage 1 exclusion is any EP who writes fewer than 100 prescriptions during the EHR reporting period. Under Stage 2, the exclusion is any EP who writes fewer than 100 medication, radiology, or laboratory orders during the EHR reporting period.

Scope of Practice

Q and A: Eligible Professionals and Core Objectives, Part 1 (Post 2 of 5)

Because most CMAs (AAMA) work under the direct supervision of “eligible professionals” (as defined in the rules of the Centers for Medicare and Medicaid Services [CMS]), this post focuses on some common questions surrounding the provisions of the Medicare and Medicaid Electronic Health Records (EHR) Incentive Program that are applicable to eligible professionals, not those provisions that are applicable to “eligible hospitals” and “critical access hospitals.”

Q: Are there different definitions of “eligible professionals” for the EHR incentive programs?

A: Yes. As in the previous post, an in-depth treatment is too lengthy to be presented. Physicians, osteopaths, and dentists are deemed to be eligible professionals under both programs, however.

Q: How do eligible professionals qualify for incentive payments under the programs? 

A: Eligible professionals qualify for incentive payments by demonstrating “meaningful use” of “certified EHR technology.” More specifically, meaningful use is proven (in part) by meeting minimum requirements for each Core Objective. The minimum requirements for each Core Objective are referred to in the CMS rules and publications as “measures.” The measures are sometimes quantitative in nature.

Q: Are there any exemptions for certain eligible professionals?

A: Yes. CMS has provided “exclusions” for eligible professionals who cannot meet some of the Core Objectives because of the small size of their practices, or the highly specialized nature of their practices.

Q: Are there partial payments if an eligible professional meets some, but not all, of the Core Objectives?

A: No. An eligible professional must meet all Core Objectives. Failure to meet any one Core Objective would result in no incentive payment.

Scope of Practice

Q and A: Medicare and Medicaid EHR Incentive Programs (Post 1 of 5)

Because most CMAs (AAMA) work under the direct supervision of “eligible professionals” (as defined in the rules of the Centers for Medicare and Medicaid Services [CMS]), this is the first of five upcoming posts focusing on some common questions surrounding the provisions of the Medicare and Medicaid Electronic Health Records (EHR) Incentive Program that are applicable to eligible professionals, not those provisions that are applicable to “eligible hospitals” and “critical access hospitals.”

Q: Are there differences between the Medicare Electronic Health Records (EHR) Incentive Program and the Medicaid EHR Incentive Program?

A: Yes. A detailed discussion of the differences is beyond the scope of this post. However, an important fact is that eligible professionals cannot participate in both the Medicare and Medicaid EHR Incentive Programs. They must choose which of the two programs they want to participate in.

Q: Are these programs mandatory?

A: In a sense, they are not. However, note the following from the Centers for Medicare and Medicaid Services (CMS) guide An Introduction to the Medicare EHR Incentive Program for Eligible Professionals:

Medicare eligible professionals who do not meet the requirements for meaningful use by 2015 and in each subsequent year are subject to payment adjustments to their Medicare reimbursements that start at 1 percent per year, up to a maximum 5 percent annual adjustment.