We have established who can perform computerized provider order entry (CPOE) for meaningful use objectives. However, what happens when someone other than a licensed health care professional or credentialed medical assistant performs CPOEand the provider counts the entry of these orders for meaningful use? Would the provider in question be penalized for such an error?
The presentation by Robert Anthony of the Centers for Medicare and Medicaid Services (CMS) helps illuminate the situation. Essentially, CMS would not levy a direct penalty against the provider, but the order in question could not be counted toward the meaningful use objective. This, in turn, could result in financial loss down the road. The text and video of Mr. Anthony’s response is below:
It’s not a penalty, but you wouldn’t be able to count those people as part of meaningful use for CPOE. … If I as a lay person go through and I complete a medication order, [CMS does not] have any jurisdiction over whether that is allowed, although there may be some local or state regulations that would cover that. As far as meaningful use is concerned, it means that you couldn’t count that order within the numerator of that particular objective. So it is possible that because of how that is calculated you might not meet that particular threshold for that objective. But it’s not a penalty that we apply for it—it’s just that you couldn’t count those orders toward the actual meaningful use objective.
As indicated in my Public Affairs article in the July/August 2013 CMA Today, an eligible professional must meet all Core Objectives. Failure to meet any one Core Objective would result in no incentive payment.