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Eligible Professionals Working at Multiple Sites

Eligible Professionals (EPs) who work at multiple sites have four general considerations while preparing for, performing, and attesting to Meaningful Use (MU).

1)  EPs attest to the EHR program and earn incentives as individuals but may work at multiple sites/physical locations. EPs have two choices associated with being part of a group or clinic practice.

i. An EP may choose to assign his or her individual payments to an organization (based on contractual requirements); or

ii. An EP may choose to use a group patient volume calculation for his or her Medicaid encounters.

Choosing either of the above does not change how an EP attests to the MU questions. An EP earns an incentive payment for his or her individual actions with CEHRT for the EPs patient population. An EP does not attest for a site or group – the individual attests for the EPs achievement of the program requirements at his or her site(s) of practice.

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

During the 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 the EP worked, excluding Place of Service 21 and 23 sites. (POS 21 and POS 23 locations are used to determine if the EP is hospital-based.) 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)  MU measures include the EPs entire unique patient population at sites with CEHRT.

During the attestation, the patient encounters question is at the beginning of the Meaningful Use Questions screen. For each of the multiple site addresses pulled from the Provider Questions screen, the attester will answer if the EP used CEHRT and enter the number of patient encounters. If all the sites have certified EHR technology, and EP cannot easily determine the patient encounters by site, the attester may divide the patient encounters by the number of sites to get the number for each site.

The number of unique patients used in the MU objectives is different from patient encounters. Unique patients (each patient is counted only once if seen more than one time during the reporting period) must include EP’s unique patients seen at all sites, excluding POS 21 or POS 23 sites.

Numerators and denominators for the MU questions and the clinical quality measures (CQMs) from the different sites must be added together if the CEHRT report does not do this for you in order to provide accurate numbers.

4) MU measures can include Public Health 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 Public Health measures associated with sending data to Immunization and other clinical data registries. Under changes made in the Stage 2 Final Rule and applicable to Stage 3, providers that use the same EHR technology and share a network, which their organization has operational control or license to use, can attest to the organizations registry status if the provider gives immunizations or contributes to the data that is electronically exchanged with the specific registry.

For more information about multiple locations and calculating CQMs across multiple sites please review this CMS document.