Eligible Professionals Working in Multiple Organizations: A complex area of meaningful use

Rich Gehrman, REACH HIT Consultant

Attesting for eligible professionals (EPs) who work in multiple organizations is an especially complex area of meaningful use (MU). It affects large institutions, independent practices and safety net clinics alike. Key issues include:

1. Which organization(s) should get an EP’s incentives and which one should attest?
2. What is the easiest way for institutions to assemble attestation data?
3. What if organizations are attesting to different menu or quality measures?

Recently REACH has worked on these questions with a collaborative of large health care systems in Minnesota. Here are some of the lessons learned.

Know Where Providers Work. Even full time employees may moonlight in urgent care or volunteer at a safety net clinic. Since combined data from all sites is needed to attest for MU, employers need to know where else their providers work. Ideally, institutions gather as much information as possible before asking EPs to complete any forms. For example, find what HR and credentialing staff already know, and check federal websites for other institutions that have proxies registered for individual EPs. Institutions also use written agreements asking EPs to provide and update information about other work.

Prepare to Share. Set up data collection and reporting procedures so it will be as easy as possible to give and receive data about a provider’s encounters in other institutions.

Separate Data from Dollars. Questions about which institutions receive which shares of an EP’s incentive payments are best addressed in a different forum from issues about assembling data needed to attest for MU.

Keep an Eye on Medicare Penalties. Some institutions may not be ready to provide data that specialty practices such as radiologists, cardiologists and anesthesiologists will need to attest to MU. For example they may not build out their EHRs to produce appropriate clinical quality measures for these groups. Conversely some specialists may not realize that they will be exposed to Medicare penalties if the institutions they work for do not plan with them in mind. It is in the interests of both partners to start talking about Medicare penalties quickly.

Remember: A provider can't split up their incentive and designate shares to more than one organization. All of the incentive has to go to just one organization. So when a provider signs over their incentive to more than one organization the last one to enter their identifying information gets the incentive. Identifying information includes the organizational NPI and their Tax ID or Employer ID.

An attestation isn't valid unless the organization doing the attesting enters numerators and denominators from all the places an EP works that have a certified EHR. This will get picked up when the CMS systems see a mismatch between all the places an EP has had Medicaid and/or Medicare encounters and the ones that were attested to. The incentive won't get approved until the attesting organization backs out the incorrect attestation and re-enters a correct one. Not only does this mean they have to make sure they find out where else a provider is working, they need to contact those other organizations and get them to share their data.