Radiologists seeking to comply with the EHR Incentive Program (aka "meaningful use") got a bit of a break last week as the Centers for Medicare and Medicaid Services (CMS) clarified its position on what counts as "seen by" an eligible professional (EP).
According to the new FAQ on the CMS website, an in-person visit with an EP clearly counts as "seen by the EP." However, in cases where the EP is consulting and not having an actual physical or telemedicine encounter with the patient, the EP may choose whether or not to include the patient in the denominator as "seen by the EP."
CMS gives the example of a cardiologist providing a one-time reading of an EKG for a patient, but the guidance should also apply to diagnostic radiologists offering teleradiology and other similar services, says Keith J. Dreyer, DO, PhD, co-chair of the American College of Radiology's IT and Informatics Committee.
The key is that the EP must have a clear and consistent policy on which patients and what services he or she counts as "seen by."
"A diagnostic radiologist could conceivably choose to limit his/her 'seen' patients to physical visits and leave out teleradiology and similar services," says Dr. Dreyer in a Friday ACR News Center post. "There is a good amount of flexibility in the current language of this new FAQ."
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