American Medical News posted an article today that summarizes comments from Dr. David Blumenthal and others delivered at an American Academy of Ophthalmology meeting last month. The article describes what an “exception” to the meaningful use rules is; how to manage the menu criteria when some do not apply to a specialist’s practice; and what to do if none of the 38 quality measures are appropriate.
CMS has posted several resources on the EHR Incentive Program website. For a quick overview, see this slide deck posted back in August with the measures and requirements — but not too much detail about the exclusions. To get into the details, the Final Rule is probably the best source. (Warning: large PDF file.) Section 495.6 on page 254 of the Federal Register states (emphasis added by me):
§ 495.6 Meaningful use objectives and measures for EPs, eligible hospitals, and CAHs.
(a) Stage 1 criteria for EPs—(1) General rule regarding Stage 1 criteria for meaningful use for EPs. Except as specified in paragraphs (a)(2) and (a)(3) of this section, EPs must meet all objectives and associated measures of the Stage 1 criteria specified in paragraph (d) of this section and five objectives of the EP’s choice from paragraph (e) of this section to meet the definition of a meaningful EHR user.
(2) Exclusion for non-applicable (i) An EP may exclude a particular objective contained in paragraphs (d) or (e) of this section, if the EP meets all of the following requirements:
(A) Must ensure that the objective in paragraph (d) or (e) of this section includes an option for the EP to attest that the objective is not applicable.
(B) Meets the criteria in the applicable objective that would permit the attestation.
(C) Attests. (ii) An exclusion will reduce (by the number of exclusions applicable) the number of objectives that would otherwise apply. For example, an EP that has an exclusion from one of the objectives in paragraph (e) of this section must meet four (and not five) objectives of the EP’s choice from such paragraph to meet the definition of a meaningful EHR user.
On the bottom of page 255 of the Federal Register, left column, the Rule continues with a section that spells out the exclusion criteria for all of the Core and Menu Set measures. It begins as follows:
(d) Stage 1 core criteria for EPs. An EP must satisfy the following objectives and associated measures, except those objectives and associated measures for which an EP qualifies for an exclusion under paragraph (a)(2) of this section specified in this paragraph…
This is where you’ll note the specific exclusions for each of the Stage 1 criteria. Here are some examples:
CPOE/Drug-Drug/Drug-Allergy/Medication: “Any EP who writes fewer than 100 prescriptions during the EHR reporting period.”
Recording Vital Signs/Height/Weight/Blood Pressure: “Any EP who either see no patients 2 years or older, or who believes that all three vital signs of height, weight, and blood pressure of their patients have no relevance to their scope of practice.”
There are exclusions listed for most of the Core and Menu set measures.
Question: If you’re a specialist, does the existence of exclusion criteria make it more likely that you will attempt to achieve meaningful use in 2011?
This post is the personal opinion of the author and does not necessarily reflect the official policy or position of the American College of Physicians (ACP). ACP does not endorse a specific EHR brand or product and ACP makes no representations, warranties, or assurances as to the accuracy or completeness of the information provided herein.