#32 Question [11-12-032-2]
CMS allows EPs, eligible hospitals, and CAHs flexibility in the ways they can calculate certain percentage-based meaningful use measures for attestation. As an EHR technology developer seeking certification to the 2014 Edition “automated measure calculation” certification criterion (45 CFR 170.314(g)(2)), must the EHR technology I present for certification be able to support every possible method of calculation that an EP, eligible hospital, or CAH could choose for a percentage-based measure?
For the 2014 Edition “automated measure calculation” certification criterion, we explained in the final rule that “for MU objectives which CMS has provided flexibility in its final rule for EPs, EHs, and CAHs to pursue alternative approaches to measuring a numerator and denominator, the EHR technology must be able to support all CMS-acceptable approaches in order to meet this certification criterion” (77 FR 54244 – 54245). This FAQ clarifies that statement in order to provide EHR technology developers with a more precise understanding of this certification criterion’s scope.
What is required for certification depends on the type of flexibility identified by CMS. In some cases, CMS identifies certain measurement flexibilities that are limited to “either/or” options. In these cases, (specifically: 1) calculating hospital admissions based on the observation services method or the all ED method; 2) recording all three vital signs or just height/weight or just blood pressure; 3) including controlled substances in the eRx measure or not; and 4) for the hospital labs send structured electronic clinical lab results objective, counting electronic lab orders received or lab orders received) EHR technology presented for certification must be able to calculate the percentage based on both identified options. The one exception to this rule is if EHR technology presented for certification for e-prescribing does not include the capability to e-prescribe controlled substances, the EHR technology developer will not need to support that alternative measure calculation.
In cases where CMS has identified measurement flexibilities that are open-ended and dependent on a unique decision by an EP, eligible hospital, or CAH at the practice/organization-level for a given EHR reporting period (such as: including more than the minimum set of encounters as relevant for medication reconciliation, or excluding certain orders from the CPOE measure because they are protocol/standing orders), then the EHR technology presented for certification is not required to support every possible method of calculation in order to meet this certification criterion. Rather, the EHR technology must support at least one calculation method for this certification criterion. We strongly encourage EHR technology developers to work with their clients and to incorporate as many of these practice/organization-level open-ended flexibilities in the EHR technology as appropriate to make the meaningful use measures as relevant as possible to their clients’ scopes of practice.