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Attesting With Multiple Practice Locations

When Providers work at more than one clinical site of practice, are they required to use data from all sites of practice to support their demonstration of MU and the minimum patient volume thresholds for the Medicaid EHR Incentive Program?

A: CMS considers these two separate, but related issues. Please read carefully, as MU calculation is different from patient volume calculation.

Meaningful Use: Any EP demonstrating MU must have at least 50 percent of his/her patient encounters during the EHR reporting period at a practice/location or practices/locations equipped with certified EHR technology capable of meeting all of the MU objectives.

EPs must include all Meaningful Use data from all locations they practiced at during their minimum continuous 90-day EHR reporting period but ONLY if those locations were equipped* with electronic health record (EHR)technology which was certified to meet outpatient meaningful use requirements. Inpatient hospital ehr data should not be included if the hospital's ehr technology was not certified to meet meaningful use for the Medicaid EHR incentive program.

equipped* means:

  • CEHRT could be permanently installed at the practice/location.
  • The EP could bring CEHRT to the practice/location on a portable computing device.
  • The EP could access CEHRT remotely using computing devices at the practice/location

Patient Volume: Calculating patient volume provides flexibility to choose locations if selecting individual volume (not group). EPs may choose one (or more) clinical sites of practice in order to calculate their patient volume. This calculation does not need to be across all of an EP’s sites of practice. However, at least one of the locations where the EP is adopting or meaningfully using certified EHR technology should be included in the patient volume. In other words, if an EP practices in two locations, one with certified EHR technology and one without, the EP should include the patient volume at least at the site that includes the certified EHR technology. When making an individual patient volume calculation (i.e., not using the group/clinic proxy option), an EP may calculate across all practice sites, or just at the one site.

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