Medicare EHR meaningful use attestation steps

To qualify for payments under the Medicare Electronic Health Records Incentive program, health care practitioners must attest compliance with the program's EHR "meaningful use" standards, using the online Medicare & Medicaid EHR Registration and Attestation System (https://ehrincentives.cms.gov/hitech/login.action). Attestation involves the completion of 37 "questionnaire" screens. Practitioners enter information on their meaningful use compliance in designated boxes. Some screens require the entering of utilization data on meaningful use measures that can be generated by certified EHR programs. (Utilization data must generally be entered in a "numerator/denominator" format.) Others require a simple "yes or no" response regarding the achievement of meaningful use objectives. Each measure's objective is included to help practitioners enter the correct information.

Practitioners must meet report on the following:

  1. All 15 of the core measures. [One of the required core measures is that practitioners report clinical qualify measures (CQMs).]
  2. Five out of 10 of the menu measures. (At least 1 public health measure must be selected.)
  3. A sum total of up to 9 CQMs; 3 core, up to 3 alternate core, and 3 additional CQMs. (If a practitioner reports a denominator of 0 for any of the 3 core measures, the practitioner must record an alternate core CQM to supplement the core measure. Therefore, a practitioner may report a minimum of 6 and a maximum of 9 CQMs depending on the resulting values in the denominators for the core measures as reported from their certified EHR.)

For each objective with a percentage-based measure, certified EHR technology must include the capability to electronically record the numerator and denominator and generate a report including the numerator, denominator, and resulting percentage for these measures. However, health care practitioners may use additional data to calculate numerators and denominators and to generate reports on all measures of the core and menu set meaningful use objectives except CQMs. In order to provide complete and accurate information for certain of these measures, practitioners may also have to include information from paper-based patient records or from records maintained in uncertified EHR technology.

Measures with exclusions have the exclusion description listed in the measure information section. (Claiming an exclusion for a specific measure qualifies as submission of that measure. If practitioners wish to claim an exclusion for which they qualify, they indicate this in the attestation system by clicking "yes" under the exclusion part of the measure question.)

During a practitioner's first year in the incentive program, the reporting period must be at least 90 consecutive days within a calendar year.

Examples of the Medicare & Medicaid EHR Registration and Attestation System attestation questionnaire pages (with marks indicating the boxes in which practitioners are to enter responses) as well as response pages, indicating attestation attempts have been successful, can be accessed here.

The Medicare Eligible Professional Attestation Worksheet has been developed by the U.S. Centers for Medicare & Medicaid Services (CMS) for use as a reference document on which practitioners can enter and organize the data required for attestation and practice the attestation process in advance. The worksheet can be accessed here.