Meaningful Use for Hospitalists: Hospital-Based Exemption and Hardship Exceptions
The Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) are promoting the adoption of electronic health records (EHR) and setting standards for their meaningful use.
The EHR Incentive Program provides incentive payments to eligible professionals and eligible hospitals that meet “Meaningful Use” requirements, as set forth in a series of regulations established by CMS and the ONC.
“Meaningful Use” requirements are a set of objectives that an eligible professional (EP) or eligible hospital (EH) must meet to qualify for incentive payments and to show that the technology is being utilized for patient care in a meaningful way. These objectives include:
Each stage of Meaningful Use is an expansion and update of program objectives. Beginning in 2015, all EPs and EHs not achieving Meaningful Use will be subject to a payment adjustment penalty.
Many hospitalists will be considered “hospital-based” eligible professionals if 90% or more of their services are performed in a hospital inpatient (Place of Service Code 21) or emergency room (Place of Service Code 23) setting. Providers meeting or exceeding this 90% threshold will not need to independently achieve Meaningful Use. However, some hospitalists, particularly those with high rates of observation care, may be considered eligible professionals and subject to Meaningful Use requirements. The Society of Hospital Medicine (SHM) is working to remedy this discrepancy, but recommends that all hospitalists check their status with Medicare.
Hospitalists practicing in nursing or post-acute facilities may qualify as EPs and be subject to Meaningful Use. Hospitalists in this situation may apply for a hardship exemption based upon their inability to control whether their institution has certified EHR technology.This exemption must be applied for yearly and is available for up to five years.