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Eligible Professionals Working at Multiple Sites

EPs sharing CEHRT across locations have some of the same considerations as individual EPs who work in multiple locations. Adopting, implementing, and upgrading (AIU) certified EHR technology (CEHRT) can be a complex financial and legal endeavor where CEHRT is often shared across multiple sites of a group or even across multiple practices to leverage various opportunities for efficiency, cost-sharing, and access to patient data. Sharing CEHRT is one mechanism through which an eligible professional (EP) can obtain CEHRT to ultimately achieve meaningful use. Sharing CEHRT among practices and providers that do not otherwise have a business affiliation is perfectly acceptable for EPs pursuing meaningful use (FAQ 10842).

Eligible professionals (EPs) who work at multiple sites have four general considerations while preparing for meaningful use, performing meaningful use, and attesting to meaningful use.

  1. This program was designed for individual eligible professionals (EPs), and EPs may work at one site or multiple physical locations.
  2. EPs attest to the program and earn incentives as individuals. EPs do have two choices associated with being part of a group or clinic practice, but neither one detracts from the overall program requirements applying to individuals:  an EP may choose to assign his or her individual payments to an organizational NPI, and he may also choose to use a group patient volume calculation for his Medicaid encounters if such a calculation is an appropriate proxy for an individual's Medicaid patient volume. Ultimately, though, an EP earns a meaningful use incentive payment for his individual actions with certified EHR technology for his patient population. An EP does not attest for a site or a group-he attests for his achievement of the program requirements at his site(s) of practice.

    During attestation, the question of whether one works at multiple sites is asked on the Provider Questions screen. If an EP worked at multiple sites during the patient volume reporting period or the EHR reporting period, the time during which meaningful use was performed, the attester must list the addresses of all the sites at which he worked, excluding Place of Service 21 and 23 sites. POS 21 and 23 locations are not applicable to this program, but POS 24 (ambulatory surgical centers) are applicable. If the EP worked full-time at one site and only part-time at another, the attester must list both sites. If two different physical locations were part of the same organization, the attester must list them as separate sites. Separate addresses=separate sites.

  3. To be a meaningful user, at least 50% of an EP's patient encounters must occur at a site with certified EHR technology (CEHRT).
  4. Part of the definition of meaningful user states, "To be considered a meaningful EHR user, at least 50 percent of an EP's patient encounters during the EHR reporting period during the payment year must occur at a practice/location or practices/locations equipped with certified EHR technology." (See FAQs 10146 and 10466.)

    During attestation, the question of patient encounters is addressed at the beginning of the Core Measures screen. The addresses of multiple sites are pulled from the Provider Questions screen. For each site, the attester is directed to answer whether the EP has CEHRT at that site and list the number of patient encounters at each site. Note that the patient encounters are different from the number of unique patients used in other aspects of the meaningful use attestation.

    If all of the sites have certified EHR technology, and one cannot easily determine the patient encounters by site, the attester may list the total patient encounters as the entry for each site. For example, if three sites have CEHRT, and the EP determines he had 1500 patient encounters total across those sites during the EHR reporting period, the attester may enter 1500 for each site.

  5. Meaningful use measures include the entire population of patients at sites with CEHRT.
  6. Unique patients are all of an EP’s unique patients at non-POS_21 or 23 sites with CEHRT. (See FAQs 10068 and 10466.) CMS FAQ 10843 provides excellent direction for tallying numerators and denominators across sites. Open a new tab to read the entire FAQ (search for the number under text), but the direction is simple—add numerators and denominators from the different sites for the core measures, the menu measures, and the clinical quality measures. EPs are not required to cross reference in case the same patient was captured as a unique patient at multiple sites. Of course, as with each site, "Please keep in mind that patients whose records are not maintained in certified EHR technology will need to be added to denominators whenever applicable in order to provide accurate numbers." If an EP does not have all patients in CEHRT, his EHR report will not provide the denominator of all unique patients required for several measures.

    Alternatively, EPs may choose to include patients seen in locations without certified EHR technology if they enter information at a practice location with CEHRT, but there are limitations to this option. See FAQ 10475.

    During attestation, the portal will require one numerator and denominator for each percentage-based measure and one yes/no attestation for implementing functions in CEHRT. None of the measures are listed by site; EPs attest with the totaled numbers for their patient population on CEHRT and affirm that yes/no functions were performed as specified. If multiple sites are using the same CEHRT on the same server, those totals may already be incorporated into the MU report or dashboard.

  7. Meaningful use measures include actions performed at multiple sites.
  8. As above, meaningful use is performed across sites of practice for an EP's entire patient population with CEHRT, and that includes the measures associated with testing. Even though Core Measure 14*-testing the exchange of key clinical information, and Menu Measure 9-testing with the immunization registry, involve testing CEHRT functionality, those tests must be performed for each physical site.  As CMS FAQ 10979 states, "there must be a single test performed for each physical location/setting. This is true even if the certified EHR technology that is used in the different physical locations is connected to the same server."

    Remember, according to the CMS technical specifications on both measures, which you can read in their entirety at the links to the individual measure pages above, "if multiple EPs are using the same certified EHR technology in a shared physical setting, testing would only have to occur once for a given certified EHR technology." In other words, the individual himself does not have to perform the test for each site, but the test must have been performed for each physical site at which an EP works. Also, all tests must be performed on or before the last day of the EHR reporting period.

    During attestation, the question of whether the measure was met, whether a test was performed, is asked only once. For Core Measure 14, attesters are asked to list a test partner from only one test. If one is attesting yes to the measure and demonstrates testing with an appropriate partner,  the EP is attesting yes to meeting the requirements of meaningful use-a test has been performed for each site. For Menu Measure 9, attesters are asked to list the date of one test, but tests for each physical site are confirmed.

*Core Measure 14 is no longer part of the core set of measures for providers performing meaningful use in 2013 and beyond.  Providers pursuing meaningful use in 2012 must continue to adhere to the specifications for Core Measure 14.