Under the Health Information Technology for Economic and Clinical Health Act of 2009 (HITECH Act), eligible hospitals and critical access hospitals must make a "meaningful use" of "certified electronic health technology" or face reductions in Medicare reimbursement during Medicare's 2015 fiscal year (which begins October 1, 2014). One of the many Stage 2 requirements includes the following one related to patient on-line access to health records:
Meaningful Use Core Measures, Measure 6 of 16
"More than 5 percent of all unique patients (or their authorized representatives) who are discharged from the inpatient or emergency department (POS 21 or 23) of an eligible hospital or CAH [must] view, download or transmit to a third party their [online] information during the EHR reporting period." (Emphasis added.)
A literal reading of this measure prompted hospitals to frequently ask whether a patient who accesses their online health information before they are "discharged" will count towards this meaningful use objective. The Centers for Medicare and Medicaid Services (CMS) posted an answer to this question that we like and think hospitals will like as well. CMS says "yes".
Here is CMS' full answer to FAQ 9824:
"The 2nd measure of the “Patient Electronic Access” core objective for hospitals and critical access hospitals (CAH) requires that more than 5 percent of the unique patients who are discharged during the EHR reporting period access an online patient portal to view, download or transmit to a third party their information about their hospital admission. The intent is to encourage patients to use online access to their health information for the active management of their care.
The denominator for this measure includes all unique patients whose discharge date from the hospital or CAH falls within the EHR reporting period selected.
Patients may choose to access their information prior to leaving the hospital, where guidance and support in using the online patient portal is still available to them. To this end, the hospital may include patients found in the denominator who access their information on or before the hospital discharge date in the numerator.
For patients who access their information after the hospital discharge date, the access must take place no later than the date of attestation in order for those patients to be counted in the numerator.
For more information about actions taken outside of the EHR reporting period and numerator calculations, please see FAQ 8231. https://questions.cms.gov/faq.php?faqId=8231"
To read this FAQ and others on the CMS FAQs webpage, click here.
We liked CMS' answer because the best time for hospitals to ensure that patients access their health records on-line may be while the patients are still at the hospital when a staff member can show them how to do it!
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