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Eligible Professionals Working at Multiple Sites

Eligible Professionals (EPs) sharing certified Electronic Health Record technology (CEHRT) across locations have some of the same considerations as individual EPs who work in multiple locations. Adopting, implementing, and upgrading (AIU) 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 EP can obtain CEHRT to ultimately achieve Meaningful Use (MU). Sharing CEHRT among practices and providers that do not otherwise have a business affiliation is perfectly acceptable for EPs pursuing MU.

EPs who work at multiple sites have four general considerations while preparing for, performing, and attesting to MU.

1. This program was designed for individual EPs, and EPs may work at one site or multiple sites/physical locations.

EPs attest to the program and earn incentives as individuals. EPs 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: (1) an EP may choose to assign his or her individual payments to an organizational NPI (based on contractual requirements); and (2) an EP may also choose to use a group patient volume calculation for his or her Medicaid encounters if such a calculation is an appropriate proxy for an individual's Medicaid patient volume. Ultimately, an EP earns a meaningful use incentive payment for his or her individual actions with CEHRT for his or her patient population. An EP does not attest for a site or a group – the individual attests for his or her achievement of the program requirements at his or her 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 EHR reporting period, the time during which MU 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 used to determine whether the EP is a hospital-based provider.) However, POS 24 locations (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.

2. To be a Meaningful User, at least 50% of an EP's patient encounters must occur at a site with a CEHRT.

Part of the CMS 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 must occur at a practice(s)/location(s) equipped with certified EHR technology”.

During attestation, the question of patient encounters is addressed at the beginning of the Meaningful Use Questions 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 MU attestation.

If all the sites have certified EHR technology, and one cannot easily determine the patient encounters by site, the attester may divide the patient encounters by the number of sites to get the entry for each site. For example, if three sites have CEHRT, and the EP determines he or she had 1500 patient encounters total across those sites during the EHR reporting period, the attester may enter 500 for each site totaling 1500.

3. MU measures include the entire population of patients at sites with CEHRT.

Unique patients are all of an EP’s unique patients at non-POS 21 or POS 23 sites. Numerators and denominators from different locations must be added together if the EHR does not do this for you. Add numerators and denominators from the different sites for the MU questions and the clinical quality measures (CQMs). At each site, keep in mind that patients without records maintained in a CEHRT 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 or her CEHRT report will not provide the denominator of all unique patients required for several measures.

During attestation, the portal will require one numerator and denominator for each percentage-based measure and one yes or 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 in CEHRT and affirm that yes or no functions were performed as specified. If multiple sites are using a networked CEHRT, those totals may already be incorporated into the MU report or dashboard.

4. MU measures include actions performed at multiple sites.

As above, MU is performed across sites of practice for an EP’s entire patient population with CEHRT, and that includes the measures associated with sending data to Immunization and other clinical data registries. The Stage 2 Final Rule changed the way shared EHR technologies are handled for testing and validation and production for Stage 2 public health agencies. Under changes made in the Stage 2 Final Rule providers that use the same EHR technology and share a network for which their organization either has operational control of or license to use can conduct the test and validation process and production transmittal for all providers in the organization that gives immunizations or a single effort to register and onboard for the Stage 2 public health measures. This also applies to Stage 3 bi-directional status.

For more information about multiple locations and calculating CQMs and Public Health measures across multiple sites please visit CMS.