Centers for Medicare & Medicaid Services, Computerized Provider Order Entry (CPOE), EHR Incentive Programs, Medicaid, Uncategorized

Eligible Professionals in the Medicaid EHR Incentive Program

I would like to note the recent update on eligible professionals (EPs) from the Centers for Medicare & Medicaid Services:

EPs that attest directly to a state for that state’s Medicaid EHR Incentive Program will continue to attest to the measures and objectives finalized in the 2015 EHR Incentive Programs Final Rule (80 FR 62762 through 62955). In 2017, Medicaid EPs have the option to report to the Modified Stage 2 or Stage 3 objectives and measures.

As a reminder, the following are considered to be EPs under the Medicaid Incentive Program:

  • Doctors of medicine
  • Doctors of osteopathy
  • Doctors of dental medicine or surgery
  • Nurse practitioners
  • Certified nurse midwives
  • Physician assistants (PAs) when working at a federally qualified health center or rural health clinic that is so led by a PA

Finally, please note the following language from the 2015 final rule, which is referred to in the previous block quote and is attached at the end of this post:

We are adopting the objective for EPs, eligible hospitals and CAHs [critical access hospitals] as follows:

Objective 4: Computerized Provider Order Entry

Objective: Use computerized provider order entry (CPOE) for medication, laboratory, and diagnostic imaging orders directly entered by any licensed healthcare professional, credentialed medical assistant, or a medical staff member credentialed to and performing the equivalent duties of a credentialed medical assistant, who can enter orders into the medical record per state, local, and professional guidelines.

Measure 1: More than 60 percent of medication orders created by the EP or authorized providers of the eligible hospital or CAH inpatient or emergency department (POS 21 or 23) during the EHR reporting period are recorded using computerized provider order entry;

  • Denominator: Number of medication orders created by the EP or authorized providers in the eligible hospital or CAH inpatient or emergency department (POS 21 or 23) during the EHR reporting period.
  • Numerator: The number of orders in the denominator recorded using CPOE.
  • Threshold: The resulting percentage must be more than 60 percent in order for an EP, eligible hospital, or CAH to meet this measure.
  • Exclusion: Any EP who writes fewer than 100 medication orders during the EHR reporting period.

Measure 2: More than 60 percent of laboratory orders created by the EP or authorized providers of the eligible hospital or CAH inpatient or emergency department (POS 21 or 23) during the EHR reporting period are recorded using computerized provider order entry; and

  • Denominator: Number of laboratory orders created by the EP or authorized providers in the eligible hospital or CAH inpatient or emergency department (POS 21 or 23) during the EHR reporting period.
  • Numerator: The number of orders in the denominator recorded using CPOE.
  • Threshold: The resulting percentage must be more than 60 percent in order for an EP, eligible hospital, or CAH to meet this measure.
  • Exclusion: Any EP who writes fewer than 100 laboratory orders during the EHR reporting period.

Measure 3: More than 60 percent of diagnostic imaging orders created by the EP or authorized providers of the eligible hospital or CAH inpatient or emergency department (POS 21 or 23) during the EHR reporting period are recorded using computerized provider order entry.

  • Denominator: Number of diagnostic imaging orders created by the EP or authorized providers in the eligible hospital or CAH inpatient or emergency department (POS 21 or 23) during the EHR reporting period.
  • Numerator: The number of orders in the denominator recorded using CPOE.
  • Threshold: The resulting percentage must be more than 60 percent in order for an EP, eligible hospital, or CAH to meet this measure.
  • Exclusion: Any EP who writes fewer than 100 diagnostic imaging orders during the EHR reporting period.

Medicare and Medicaid Programs; Electronic Health Record Incentive Program—Stage 3 and Modifications to Meaningful Use in 2015 Through 2017; Final Rule

Affordable Care Act (ACA), EHR Incentive Programs, Meaningful Use, Medicaid, Medicare, Scope of Practice

Congressional Action on the ACA

As our government transitions to a new administration, the following question has become increasingly common:

Would amendments to or repeal of the Affordable Care Act (ACA) affect medical assistants’ scope of practice?

The answer? Almost certainly not.  The scope of practice of medical assistants is determined primarily by state law.  An exception is the meaningful use order entry requirements of the Medicaid Electronic Health Record Incentive Program.  The Medicaid Incentive Program was not created by the ACA and would not be impacted by any amendments to or repeal of the Affordable Care Act.  Consequently, it is highly unlikely that the scope of practice for medical assistants will be impacted by congressional action on the ACA.

Computerized Provider Order Entry (CPOE), EHR Incentive Programs, Medicare, On the Job

OIG Initiates Audit Program of the Medicare EHR Incentive Program

As part of its Work Plan for Fiscal Year 2015, the Office of Inspector General (OIG) of the Department of Health and Human Services is initiating an audit program of the Medicare Electronic Health Record (EHR) Incentive Program. This audit program will be conducted in addition those already being performed by Figliozzi and Company, the audit contractor for the Centers for Medicare and Medicaid Services.

Any eligible professionals (EPs) who received incentive payments from Jan. 1, 2011, to June 30, 2014, are eligible to be randomly selected for auditing. The OIG will review certain meaningful use measures to determine whether selected EPs incorrectly received any incentive payments, and whether those EPs have adequately protected patients’ health information created or maintained by the EHR. As part of the auditing process, the agency will request specific information and documentation of compliance with the meaningful use measures under review.

To prepare for the possibility of an audit, all EPs should review their documentation for each meaningful use measure and for every year an incentive payment was received. For more information, visit the CMS meaningful use meaningful use audits webpage and access the Medical Group Management Association’s Meaningful Use Resource Center.