Supporting the Electronic Referral Loop by Sending Summary of Care Information
Does your denominator seem lower than it should be for this measure? Does it look like your group or individual clinicians are excluded when you know more than 100 referrals have been ordered for your patients during the 90+ day reporting period? We have been seeing this trend with our clients.
We learned from Allscripts yesterday that the eligible clinician is required to sign off on the encounter in order for a referral to count in their denominator. It does not matter if ancillary staff order the referral on behalf of the clinician, if that clinician does not personally sign off the encounter, their denominator will not increment. As a result, you may appear excluded when you actually are not.
We also asked CMS and received the following Q/A response:
Q: If a referral is ordered on behalf of a provider by a member of the provider's staff, does that count as a referral? (i.e., the provider has instructed the staff member to send health information, but has not signed off on it directly)
A: The denominator includes the number of transitions of care and referrals during the performance period for which the MIPS eligible clinician was the transferring or referring clinician. This includes referrals within the group.
As long as the CEHRT is reflected under the eligible clinician's NPI, CMS does not dictate the internal workflow used by a MIPS eligible clinician. Therefore, if your internal policy allows for other staff to perform functions related to referrals under the MIPS eligible clinician's NPI, it is a viable option.
What should you do?
Evaluate your workflow to see if you need to make the change and require your clinicians to sign off on all referrals.
Make sure you export at least one Summary of Care document, even if you are excluded, so that in the case of an audit you do not risk losing all of your Promoting Interoperability points.
Take ACTION – the last 90 day reporting period begins in October!
Other options:
If you are a server onsite client, eHealth does offer custom report options based on your CEHRT. If you would like us to assist you with a report that is in line with CMS’ description of the specification for this measure, please contact us here.