No need to attest on every meaningful use measure if you use exclusions

It's important that you understand "exclusions" and how to use them, because they could allow quite a bit of flexibility in your meaningful use reporting and attestation.

Many meaningful use (MU) objectives in the Centers for Medicare and Medicaid Services Final Rule include a provision allowing the practitioner to attest that they did not have any patients or insufficient actions on which to base a measurement of that particular objective during the electronic health record reporting period. There are several that offer no exclusions and must be reported, such as the following core set objectives: Maintaining a Problem List, Maintaining a Medication List, Maintaining a Medication Allergy List, Clinical Decision Support, etc.

Examples of core set objectives that include an exclusion are:

CPOE for Medication Orders: If you write fewer than 100 prescriptions during the reporting period, you can exclude this objective.
E-prescribing: If you write fewer than 100 prescriptions during the reporting period, you can exclude this objective.
Smoking Status for patients 13 and over: If you see no patients older than 13 during the reporting period, you can exclude this objective.
Clinical Summaries: If you have no office visits during the reporting period, you can exclude this objective (not likely).
Electronic Copy of Health Information for patients who request: If no patients request one during the reporting period, you can exclude this objective.

Remember that the exclusions listed above apply to your EHR reporting period. So, in your first year, you only have to consider the 90-day reporting period. That short reporting period might allow some of you to exclude the prescription-related objectives in your first reporting year but not in subsequent years (requiring you to report for the full year). If you're able to attest to an exclusion of a core set objective, the objective excluded is removed from consideration (in determining whether you are a meaningful user), and you have to satisfy the remaining core set objectives.

The Menu Set also includes exclusions for some measures. Examples of Menu Set objectives that include an exclusion are:

Lab Test Results Imported: If you order no lab tests during the reporting period, you can exclude this objective.
Patient Reminders: If you have no patients 65 or older or no patients 5 and younger during the reporting period, you can exclude this objective.
Medication Reconciliation: If you are not a recipient of any transfers of care during the reporting period, you can exclude this objective.
Drug Formulary Checks: If you write fewer than 100 prescriptions during the reporting period, you can exclude this objective.
Summary of Care Record: If you neither transfer a patient to another setting of care nor refer a patient to another provider during the reporting period, you can exclude this measure.

Excluding a Menu Set objective would remove the objective from consideration (in determining whether you are a meaningful user), and reduces the number of Menu Set objectives you must meet.

For example, if you were to attest that you didn't order any lab tests during the reporting period, instead of having to attest to five of the 10 Menu Set meaningful use objectives (as stated in the Final Rule), you would only need to satisfy four of the nine remaining meaningful use objectives included in the Menu Set. Therefore, it is may possible for some of you to exclude two or three Menu Set objectives and only have to attest for two or three of the remaining objectives in the Menu Set.

As always, you can email questions to me and I'll do my best to respond quickly: jeff@HCMA-Consulting.com.