MU2 Objectives and EP Attestation - Mental Health Behaviour

devi-openemr wrote on Sunday, May 18, 2014:

Team,

I have a question on MU2 - Mental Health Behaviour EPs core and menu measure -

There are some measures which are not applicable for mental behavioural health. For instance
Image Results (CORE)
Immunization (MENU)
Transmission to Immunization Registries (MENU)
Syndromic Surveillance (MENU)

Ref: http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/Stage2_MeaningfulUseSpecSheet_TableContents_EPs.pdf

Is there any exceptions (in core or menu) for EPs in getting the Attestation? Or they need to report all the measures, though it is not applicable.

Please do share your views.

Thanks
Devi

fsgl wrote on Sunday, May 18, 2014:

If you click on the link for Imaging Results, there will additional information for that Menu Measure with descriptions about exclusions.

Psychiatrists should be able to use all exclusions when they report each measure.

devi-openemr wrote on Monday, May 19, 2014:

Thank you.

I agree - Physicians can go for exclusion and the explanation in the link helps. Even then i’m not able to clearly conclude because of the statement
"No Access – None of the imaging providers used by the EP provide electronic images and any explanation or other accompanying information that are accessible through their CEHRT at the start of the EHR reporting period."

But my question is - is there any exclusion for Behavioural Health EHR vendor in getting the module exempted from certification, as those modules are really not used by their physicians.

Thanks

yehster wrote on Monday, May 19, 2014:

No, exceptions are only applicable when an eligible provider(EP) attests. There is no provision for exceptions for vendors during the certification process.

fsgl wrote on Monday, May 19, 2014:

Note that certification and attestation are 2 distinct procedures. An EHR, which does not have all the modules in place, will not be certified. Period. ONC (the certifying governmental agency) will not grant any exemptions. Physicians cannot use an uncertified EHR to demonstrate Meaningful Use. The above cited document lists some of the requirements which a physician will state in a legally binding format (attest) that he has completed.

The exclusion does not work from the vendors’ end. Vendors are not part of the equation when it comes to attestation. A certified EHR, by definition, will have the module. If the physician is unable to use the existing module to fulfill this measure, then the exclusions are available.

The “No Access” provision concerns the ability of the hospital’s Imaging department or that of a stand-alone facility to provide the electronic images to the physician. If the Imaging facility lacks this capability, the physician can deploy that exclusion.

devi-openemr wrote on Tuesday, May 20, 2014:

Thankyou. Really this helps.

fsgl wrote on Tuesday, May 20, 2014:

You’re welcome.

Our Academy does a very good job with their attestation guides. Although written specifically for Ophthalmology, it is useful for other specialties. Here is the link.