[EHR Incentive Programs]  For the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs, how should an eligible professional (EP), eligible hospital, or critical access hospital (CAH) attest if the certified EHR vendor uses 2011 edition Certified EHR Technology for the first part of 2013 and 2014 edition Certified EHR Technology for the remainder of 2013?

If an EP, eligible hospital or CAH switches from 2011 edition Certified EHR Technology to 2014 Edition Certified EHR Technology during the program year, the data collected for the selected menu objectives and quality measures should be combined from both of the EHR systems for attestation.  The count of unique patients does not need to be reconciled when combining from the two EHR systems.

If the menu objectives and/or clinical quality measures used are also being changed when switching certified editions, the menu objectives and/or quality measures collected from the EHR system that was used for the majority of the EHR reporting period should be reported.

Created on 8/20/2013



CMS also finalized a policy that will give EPs who practice at multiple locations and eligible providers (EPs/EHs/CAHs) who switch CEHRT during the EHR reporting period some flexibility as to the method for counting unique patients in the denominators.


For EPs who practice in multiple locations, the EP may count  a unique patient across all locations equipped with different CEHRT (e.g., one patient seen at three locations with different CEHRT counts once) or at each location equipped with CEHRT (e.g., one patient seen at three locations would count thrice).


In cases where an eligible provider switches certified EHR technology products at a single location during the EHR reporting period, the provider will have the flexibility to count a patient as unique on each side of the conversion and not across it (e.g., one patient seen before the conversion and after the conversion to new CEHRT could be counted once or twice). Eligible providers in these scenarios must choose one of these methods for counting unique patients and apply it consistently throughout the entire EHR reporting period.