Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.
A reader asked how a physician meets meaningful use when some of his encounters occur at a nursing home where there is no certified EHR. Specifically, she wanted to know if the physician was expected to bring his own EHR (hardware and software) to the facility to document encounters there. The answer is “no”—he limits his reporting to encounters that take place in the clinic setting.
A somewhat similar situation is faced by physicians who are affiliated with two (or more) different practices, where not all of the practices(s) are equipped with certified ambulatory EHR technology. In this case, the physician reports on the encounters where a certified EHR is available. The only caveat is that to be eligible for an EHR incentive, the physician must have at least 50% of his encounters at location(s) that do have a certified EHR.
If you have other questions you’d like answered about meaningful use or the EHR incentive money. Please send in your question on our contact us page.
What about when it comes to penalties if more than 50% of the facilities do not have an EHR?
Mark,
You should take a look at this previous MU Monday post about the penalties: https://www.healthcareittoday.com/2011/11/28/the-low-down-on-future-meaningful-use-penalties-%E2%80%94-meaningful-use-monday/
Although, I think the EHR penalties aren’t dependent on adoption or not. The subsequent increases might be influenced by the adoption, but I believe the penalties are coming either way. Unless of course HHS or someone changes something and delays the penalties for everyone.
Mark,
In response to the comment you posted, the Secretary of HHS does have the option to raise the penalty for noncompliance with meaningful use to 4% and 5% for 2019 and 2020, respectively, if the proportion of eligible professionals who are meaningful users is less than 75%. This relates to professionals, but not to facilities.
If it’s Medicaid then they can just do an AIU and have the systems installed in time for the MU attestation. They may choose not to participate for a year or so and get their stuff together. Medicare they have to have a system installed. Now here is something to consider. They can have an EHR at one site and not at the other, however they can make sure that the provider goes to the EHR site and enter all of the information into the EHR at the site with the EHR untill all sites are installed. Finally it’s not that hard to simply install a PC and access the EHR site from the non EHR site.