Should specialist opt out of doing vitals for Meaningful Use ?

There has been some confusion surrounding the MU Core requirement to do vital signs and related exception, i.e. should providers report an exception for this measure

Meaningful Use requires all eligible providers to do vitals (BP, Height and Weight) for at least 50% of their patients during the reporting period of 3 months. CMS allows an exception to this rule for providers who do not consider vitals as part of the scope of their practice. However, CMS does not state much more then allowing the specialist to be excluded form this requirement if they feel the vitals is not scope of their practice.  They do not issue any guideline or provide specific information for any specialty.

Please see below the official language from CMS guideline pertaining to the vital signs core requirement.

EXCLUSION: An EP who sees no patients 2 years or older would be excluded from this requirement. Additionally, an EP who believes that all three vital signs of height, weight, and blood pressure have no relevance to their scope of practice would be excluded from this requirement. EPs must select NO next to the appropriate exclusion, then click the APPLY button in order to attest to the exclusion.”

In my opinion the CMS is placing the burden of proof on the specialist who choose to be excluded from this measure. When a provider attests for MU with CMS they are simply reporting on their percentages/numbers for the various measures. They are not verifying the numbers before they make a payment to providers. However, CMS will be doing random audits of providers who received the MU Incentive Payment and ask them to show the supporting documentation and proof of any exclusion they selected. Just doing the vitals for all patients is a lot safer option then trying to opt out for specialist. In the current healthcare climate no one can be certain how future regulations associated with Stage 2 and Stage 3 MU will pan out for healthcare providers.

Every provider attesting on MU measures is independently responsible for the attested measures and exclusions.

The Medicare EHR Incentive Program 
The Medicare EHR Incentive Program will provide incentive payments to eligible professionals, eligible hospitals, and CAHs that demonstrate meaningful use of certified EHR technology.
Participation can begin as early as 2011.
Eligible professionals can receive up to $44,000 over five years under the Medicare EHR Incentive Program. There’s an additional incentive for eligible professionals who provide services in a Health Professional Shortage Area (HSPA).
To get the maximum incentive payment, Medicare eligible professionals must begin participation by 2012.
Incentive payments for eligible hospitals and CAHs may begin as early as 2011 and are based on a number of factors, beginning with a $2 million base payment.
Important! For 2015 and later, Medicare eligible professionals, eligible hospitals, and CAHs that do not successfully demonstrate meaningful use will have a payment adjustment in their Medicare reimbursement.
The Medicaid EHR Incentive Program
The Medicaid EHR Incentive Program will provide incentive payments to eligible professionals, eligible hospitals, and CAHs as they adopt, implement, upgrade, or demonstrate meaningful use of certified EHR technology in their first year of participation and demonstrate meaningful use for up to five remaining participation years.
The Medicaid EHR Incentive Program is voluntarily offered by individual states and territories and may begin as early as 2011, depending on the state. Check with your State Medicaid Agency  for more information.
Eligible professionals can receive up to $63,750 over the six years that they choose to participate in the program.
Eligible hospital incentive payments may begin as early as 2011, depending on when the state begins its program. The last year a Medicaid eligible hospital may begin the program is 2016. Hospital payments are based on a number of factors, beginning with a $2 million base payment.
There are no payment adjustments under the Medicaid EHR Incentive Program.
Source: http://www.cms.gov/EHRIncentivePrograms/

The Medicare EHR Incentive Program 

  • The Medicare EHR Incentive Program will provide incentive payments to eligible professionals, eligible hospitals, and CAHs that demonstrate meaningful use of certified EHR technology.
    • Participation can begin as early as 2011.
    • Eligible professionals can receive up to $44,000 over five years under the Medicare EHR Incentive Program. There’s an additional incentive for eligible professionals who provide services in a Health Professional Shortage Area (HSPA).
    • To get the maximum incentive payment, Medicare eligible professionals must begin participation by 2012.
    • Incentive payments for eligible hospitals and CAHs may begin as early as 2011 and are based on a number of factors, beginning with a $2 million base payment.
    • Important! For 2015 and later, Medicare eligible professionals, eligible hospitals, and CAHs that do not successfully demonstrate meaningful use will have a payment adjustment in their Medicare reimbursement.

The Medicaid EHR Incentive Program

  • The Medicaid EHR Incentive Program will provide incentive payments to eligible professionals, eligible hospitals, and CAHs as they adopt, implement, upgrade, or demonstrate meaningful use of certified EHR technology in their first year of participation and demonstrate meaningful use for up to five remaining participation years.
    • The Medicaid EHR Incentive Program is voluntarily offered by individual states and territories and may begin as early as 2011, depending on the state. Check with your State Medicaid Agency  for more information.
    • Eligible professionals can receive up to $63,750 over the six years that they choose to participate in the program.
    • Eligible hospital incentive payments may begin as early as 2011, depending on when the state begins its program. The last year a Medicaid eligible hospital may begin the program is 2016. Hospital payments are based on a number of factors, beginning with a $2 million base payment.
    • There are no payment adjustments under the Medicaid EHR Incentive Program.
  • Source: http://www.cms.gov/EHRIncentivePrograms/