Question

How do we determine which medications count in the denominator for electronic  prescribing?


Response

This in response to MEDITECH’s recent change on  January 22, 2016 for excluding over-the-counter prescription for the  electronic  prescribing objective measure (EH Objective Measure 4 and EP Objective Measure 2).

 

The definition of prescriptions for the purposes of electronic prescribing has been defined by CMS to exclude over-the-counter (OTC) medications. This definition has not changed since the beginning of Meaningful Use in 2011 Edition CEHRT. The exclusion is based on the definition of a valid and permissible prescription, not based on a data attribute associated with the drug. The Certified EHR Technology is required to track and include only permissible prescriptions.

 

As of January 22, 2016, MEDITECH has included a new feature (CS RXM 3454) to allow formulary service vendor over-the-counter (OTC) indicators to be filed and sent to Data Repository with any new prescription for reporting purposes.  MEDITECH has added the ability to identify OTC in the RXM Drug Dictionary for the purposes of exclusion from the denominator criteria for this measure.

 

Acmeware has reviewed the changes and will be including the OTC exclusion reporting in the next release of OneView Hospital Quality and Physician Quality for electronic prescribing measure reporting. This change in OneView will exclude OTC drugs from the denominator criteria for this measure.

 

This change does not impact hospitals or providers who have attested or plan to attest for 2015.


For hospitals or provers who have already attested and have entered numerator and denominator information during the Medicare Electronic Health Record (EHR) Incentive Program attestation from certified EHR technology, but subsequently discovered that the method of calculation included in the software was wrong. If CMS conducts an audit you will not be held responsible for the difference between what you reported and what the updated software calculates. CMS does not plan to conduct an audit to find hospitals or providers who relied on flawed software for their attestation information. CMS realizes hospitals and providers rely on certified EHR software for accuracy of reporting, and CMS believes that most hospitals and providers who were improperly deemed meaningful users would have met the requirements of the EHR Incentive Programs using the updated certified EHR technology.


For more information about the FAQ, please review FAQ6097.


If you have any questions please contact your Consultant Analyst or email us at OneView Support.