Dr. Kirchner Explains Meaningful Use Objectives and Exclusions

Eyefinity’s Chief Professional Officer, James Kirchner, OD, continues his series to help you understand meaningful use objectives and exclusions:  

Dr. Kirchner

In my previous Trends and Tactics e-mail, we made it through all of the CMS meaningful use objectives. As you’ll remember, there are 25 objectives—defined in the CMS Final Rule. Of those objectives, 15 are considered core, and CMS expects the Eligible Professional (EP) to fulfill them. The remaining 10 are menu objectives and CMS allows EPs to fulfill just 5.

Last year I stated that CMS provided a set number of exclusions that an EP can use for a designated objective, and that by claiming the exclusion, the objective is fulfilled.

In this edition, I’m presenting the designated exclusions with their particular objective. Objectives not included on this list don’t have exclusions. Again, you only need to fulfill 5 menu objectives, so exclusions become very valuable in regard to fulfilling the 15 core objectives.

Core Objectives:

1. CPOE (Computer physician order entry) for medication orders

More than 30% of unique patients with at least 1 medication in their medication list seen by the EP must have at least 1 medication order entered using CPOE

Exclusion – EP writing less than 100 prescriptions during reporting period

2. Record and chart vital signs

Height, weight, blood pressure, calculate and display BMI, and plot/display growth charts (for children 2 – 20 years old), including BMI; for more than 50% of all unique patients over age 2 have height, weight, and blood pressure recorded as structured data

Exclusion – EP seeing no patients 2 years or older or believes that all three vital signs of height, weight, and blood pressure have no relevance to their scope of practice

3. Record smoking status for patients 13 years old or older

More than 50% of all unique patients 13 years or older seen by the EP must have smoking status recorded as structured data

Exclusion – An EP who sees no patients 13 years or older

4. Generate and transmit permissible prescriptions electronically (eRx)

More than 40% of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology

Exclusion – EP writing less than 100 prescriptions during reporting period

5. Provide patients with an electronic copy of their health information

Including diagnostic test results, problem list, medication lists, medication allergies, discharge summary, procedures upon request; more than 50% of all unique patients of the EP who request an electronic copy of their health information are provided it within 3 business days

Exclusion – EP that has no requests during the reporting period

6. Provide clinical summaries for patients for each office visit

Clinical summaries provided to patients for more than 50% of all office visits within 3 business days

Exclusion – EP that has no office visits during the reporting period

Menu Objectives (Only Need to Satisfy 5 Out of 10):

1. Implement drug-formulary checks

The EP has enabled this functionality and has access to at least one internal or external drug formulary for the entire EHR reporting period

Exclusion – EP who writes fewer than 100 prescriptions during reporting period

2. Incorporate clinical lab-test results

On to certified EHR technology as structured data

Exclusion – EP who orders no lab tests whose results are either a positive/negative or numeric format during reporting period

3. Send reminders to patients per patient preference for preventive/follow-up care

More than 20% of all unique patients 65 years or older, or 5 years old or younger were sent an appropriate reminder during the EHR reporting period

Exclusion – EP who sees no patients 65 years or older, or 5 years or younger with records maintained using EHR technology during reporting period

4. Provide patients with timely electronic access to their health information

Including lab results, problem list, medication lists, medication allergies within 4 business days of the information being available to the EP; more than 10% of all unique patients seen by the EP are provided timely (available to the patient within 4 business days) electronic access to their health information subject to the EP’s discretion to withhold certain information

Exclusion – EP that neither orders nor creates lab tests or information that would be contained in the problem list or medication list during the reporting period

5. The EP who receives a patient from another setting of care, or provider of care, or believes an encounter is relevant should perform medication reconciliation EP performs medication reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of the EP

Exclusion – EP who was not the recipient of any transitions of care during the reporting period

6. The EP, who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care, should provide summary of care record for each transition of care or referral

EP, provides a summary of care record for more than 50% of transitions of care and referrals

Exclusion – EP who neither transfers a patient to another setting nor refers a patient to another provider during the reporting period

7. Capability to submit electronic data to immunization registries or Immunization Information Systems and actual submission in accordance with applicable law and practice

Performed at least one test of certified EHR technology’s capacity to submit electronic data to immunization registries

Exclusion – EP who administers no immunizations during the reporting period or where no immunization registry has the capacity to receive the information electronically

8. Capability to submit electronic syndromic surveillance data to public health agencies and actual submission in accordance with applicable law and practice

Performed at least one test of certified EHR technology’s capacity to provide electronic syndromic surveillance data to public health agencies

Exclusion – An EP who does not collect any reportable syndromic information during the reporting period or does not submit such information to any public health agency that has the capacity to receive the information electronically

Using exclusions allows you to fulfill meaningful use, but they’re options only. Colleagues have told me that they plan to fulfill all of the 25 objectives and not use exclusions. That is a bold commitment, but not necessary to fulfill meaningful use in Stage 1.

Remember to register with CMS now. You don’t have to have your certified EMR in place to register.

Check out this excellent CMS Registration video tutorial.

35 Replies to “Dr. Kirchner Explains Meaningful Use Objectives and Exclusions”

  1. I saw in an article that for stage 2 we are required to have 5 CDS (clinical decision support). How do we set that up? Officemate had set up the first one (macular degeneration).
    Tim Masden, OD

    1. Hello, Dr. Masden.

      You are correct. You will need five clinical decision support rules in place for stage 2. Stage 2 is not required in 2013. You can attest to 90 days of stage 2 meaningful use in 2014. We will be updating our meaningful use training materials for stage 2 soon. Additionally, we will release a version of OfficeMate/ExamWRITER that is certified for stage 2 soon.

      To create additional clinical decision support rules, follow the instructions on page 17 of the Achieving Meaningful Use with OfficeMate/ExamWRITER document.

  2. Regarding menu set measure #10 test of EHR technology to provide electronic syndromic surveillance. I’ve tried to locate a local public health agency to use to register for this but have not been successful. I went online to the Department of Health website where it says EPs in New Jersey will use the EpiCenter system. However, I have not been successful in getting any information from them. What should I do.

    1. Dr. Carter:

      When it comes to menu set measures 9 or 10, you must complete one of them, but neither are very applicable to optometry. If you can claim an exclusion for either menu measure 9 or 10, I’d suggest doing so. Claiming an eligible exclusion is effectively the same as fulfilling the measure.


  3. I reported and received my stimulus monies for 2011. I have continued my EMR documentation into 2012. Where do I go to find the instructions for the 2012 reporting? When are the deadlines? Do I just have to go through the attestation for 2012 like I did for 2011? Since I qualify for phase 1(I think), do I have to report 90 days or the full year 2012? If it is the full year 2012, I am assuming that I cannot attest until January 2013? If this is the case, do I need to do anything on the meaningful use/cms website prior to attestation since I am already registered from 2011? Thanks.

    1. Dr. Bond:

      You will attest to meaningful use exactly as you did before. If you are participating in the Medicare program, you will again attest through the EHR Incentive Program Registration and Attestation System. A visual guide to the system can be found here: https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/downloads/EP_Attestation_User_Guide.pdf . If you participated in a Medicaid program, you will again attest through your state’s Medicaid system.

      You do not need to reregister.

      The 90-day reporting period is only for your first year. Since this is your second year, you will be reporting on the full 2012 calendar year. Obviously, you won’t be able to report on 2012 until January 2013 (or after your last day of business in 2012). You will be able to attest to your 2012 meaningful use activities through February 28, 2013.

      Additionally, you will be reporting on stage 1 of meaningful use. Stage 2 will not begin until 2014.

      I hope that helps!

  4. I am stuck on Core #10 CQM, It says we must complete 3 of the 6. We do not record weight, BP, immunization or influenza information. The only one we record is smoking assessment. Is it necessary for us to record weight and BMI to qualify for MU? Or did i fill out something incorrectly somewhere leading up to this question in attestation?

    Thank you.

    1. Karla:

      If the denominator for any of the core CQMs (hypertension, tobacco use, and adult weight screening) is zero, you must report on one of the alternate CQMs (BMI, influenza vaccination, and childhood immunization) If none of the alternate CQMs apply to your practice, you must report all three with a denominator of zero. It sounds like you’ll be reporting on tobacco use and entering zeros in the denominators for the other core and alternate CQMs.

      Regardless of which core and alternate measures you report, you must also report on three additional measures from a list of 38. For more information, check out the video for core measure 10 in our Meaningful Use Starter Kit.

      Hope that clears things up a bit.

      1. I wanted to get your thoughts on the final rules I found in the Federal Register: http://www.gpo.gov/fdsys/pkg/FR-2012-09-04/pdf/2012-21050.pdf It starts in the middle of the page on P. 53975 (or page 8 in the pdf file). It sounds to me like this they’re separating BP from weight & height, and would clarify that we can take the exclusion if we only occasionally take BP and don’t record weight & height. But I’m a little concerned that if I claim the exclusion this year, and then next year start recording BP only on most of my patients, does that sound strange? Maybe they’d think that it would go along with the whole point of this process, that it encourages us to gather & analyze a little more data to provide better care?

      2. Dr. Heffron:

        You are correct. The exclusions for recording height and weight and recording blood pressure will be separated. This is optional in 2013, which means you can continue to meet this measure the same way you met it in 2011 and 2012. This tip sheet from CMS explains the 2013 changes to stage one in plainer language: http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/Stage1ChangesTipsheet.pdf .

        As far as how strange it might look that you are suddenly recording BPs, I can’t answer that. There is so little information available about meaningful use audits, that it hard to say whether that kind of change will raise a red flag against your prior years’ attestations. And if it does, whose to say the scope of your practice didn’t change that year? Perhaps some of our readers can chime in.


  5. I am running OfficeMate 10.5 and have most of my MU objectives complete now. However, when I run a report for the reporting period, Menu Set #5 (Patient Electronic Access) is showing 0/725. Where is this recorded in OfficeMate to alter the Numerator? Also, is there a way to go back and set Patient Reminders (Menu Set #4) during the reporting period after the fact. When I post fees, I am prompted to set a “recall” period, which I do for 1 year recall. This does not seem to coincide with Patient Reminders. Are these two separate things and if so, how do I set a patient reminder?


    1. Dr. Bond:

      The Menu Measure 5 numerator represents the number of CCRs (continuity of care records) that you upload for patients to access electronically within four days of the encounter. If you did not upload any CCRs from the eDocuments window during the reporting period, don’t worry. Remember, you only need to choose five of the ten Menu Set measures, so you can choose another measure to report.

      Menu Set measure 4 can be difficult to meet in only a few months, but gets easier as you have more reporting time. Not only do you have to set up recalls, but you also have to run them. Refer to this knowledge base article for a complete explanation: http://www.officemate.net/omkb/Article.aspx?id=27834&cNode=3R7P0N . Again, you can chose a different measure to report.

      I know that you are well on your way to attesting to meaningful use, but other readers might benefit from our Meaningful Use Starter Kit: http://www.officemate.net/mu_starter_kit.aspx . The starter kit features online videos that break down and describe how to meet each measure, check lists for doctors, technicians, and staff to keep track of their part in achieving meaningful use, and frequently asked questions.

      I encourage anyone who has questions about how a numerator or denominator is calculated or what constitutes an exemption from any of the measures to refer to the “Achieving Meaningful Use with OfficeMate/ExamWRITER” document on the starter kit: http://www.officemate.net/mu_starter_kit.aspx .

  6. Than you so very much for all your input. The
    Problem I am having is the Clinical Summary
    To patients in 3 business days. I have not
    Been following the 3 days restriction.
    Any remedy at this late stage ?
    Thank you for all your help.

  7. Dr. Kirchner,

    We are currently using Officemate 10.0 and planning to attest at the end of the year. My question is concerning 9 and 10 of the menu set objectives. I realize that we must select at least one of these objectives either by excluding it or fulfilling it. I attended an EMR lecture at the East/West Eye Conference in October and the lecturer stated that we could exclude one or the other, but could not exclude both of these measures. I have not been able to find this in print anywhere. Could you please advise as to whether we can exclude both objectves 9 and 10 and count them as having met two of the objectives in the menu set.

    Thank you.

    Arthur Duppstadt OD

    1. Thanks for your question Dr. Duppstadt –

      According to CMS Medicare incentive guidelines, an EP must fulfill at least one of the public health menu measures #9 or #10. If neither applies to your scope of practice, then you must pick at least one and fulfill it by exclusion. An EP cannot exclude both measures and use that towards fulfilling the required 5 out of 10 Menu measures. The CMS weblink answer is:


      Dr. James Kirchner

  8. Thanks for your reply on how to generate the meaningful use calculations in OfficeMate/ExamWRITER. Most of my reporting looks adequate based on the requirements. However, I am coming up with 0/545 for Core #9 Record Smoking Status. My technicians, for the most part, have been recording the smoking status of patients in the social history. This being the case, why does my report show zero for the numerator and 545 for the denominator, yielding a zero percentage?


    1. Dr. Bond:

      Ensure that your technicians are also going beyond selecting (or not selecting) the Patient Does not Use Tobacco check box. Be sure also to indicate whether the patient ever smoked, when he/she stopped, how often or how much, and recommended remediation for current smokers. Use the check boxes, radio buttons, and text boxes; free-form notes will not count toward your meaningful use counts. Do this for a couple of patients and rerun your meaningful use reports to see if the numerator changes. If you still have a zero percentage, contact our customer care team at 800.9425353.


  9. Do you feel that optometrists who take too many exclusions and put too many zeros in the denominator are hurting the perception of our profession in the eyes of decision makers in Washington? We have fought for years to be considered medical professionals and then it seems we are not doing many things that medical doctors do.

    1. Dr. Wagner:

      Optometry has worked very hard over the last 40 years to mature as a healthcare profession. We have fought many scope-expansion battles in state legislatures and richly provided any new service gained from these legislative efforts. Optometry should be proud to be a valuable member of the American healthcare delivery team. Optometry’s involvement in the HITECH program is another significant effort in portraying our commitment to the innovation and the delivery of efficient, quality healthcare. As eligible providers (EPs) in the meaningful use initiative for electronic health records (EHRs), we should participate in a manner that reflects this commitment. The government’s goal is to get as many EPs and hospitals using EHRs in a meaningful way by the year 2016 as is possible. In doing so, rules have been created to allow us to fulfill meaningful use objectives successfully. A part of this system is the use of exclusions in fulfilling objectives. There are no negative connotations for using the exclusions for objectives if they are appropriate for the EP. There is no harm to any profession or professional in stage 1 of meaningful use for using exclusions or declaring a zero in the denominator for quality reporting measures if that is the honest response. It is the act of using the EHR that’s important in stage 1. Remember, these meaningful use rules are not just for optometry but for EPs of all health professions. We will all be fulfilling meaningful use in the same manner.

      James Kirchner, OD
      Chief Professional Officer, Eyefinity

  10. 10/28/2011
    I would like to know if the CMS Quality Reporting criteria applies to Optometric offices. When on the attestation site, I went through all the meaningful use and menu set measures. Then, I had to answer at least 6 CMS Quality Report measures most of them don’t even pertain to our office. Thank you Sue

  11. Dr. Kirchner,

    Is there a way in the OfficeMate reports to extract the necessary data to record the numerator/denominator for the various Core Set Objectives. If not, how do you recommend obtaining this information?

    Michael Bond, OD

    1. Dr. Bond:

      To run your meaningful use report and extract your numerator/denominator data from OfficeMate/ExamWRITER, open OfficeMate Administration, click Reports, and select CMS Meaningful Use Reporting. For complete instructions, refer to the “Reporting Immunization, Public Health, and Meaningful Use” chapter of the OfficeMate Administration User’s Guide, which can be found under the Help menu within the software.


  12. When finalizing a chart, there is a box we can check ‘Exam is Billable/Reportable [MU]; do we check this box for only our Medicare patients? Does this box determine whether or not it’s counted in the reports?

    1. Hi, Heather.

      The following explanation of the Exam is Billable/Reportable [MU] check box comes from the ExamWRITER Help, which is available by pressing F1 within any window in ExamWRITER:

      Select Exam is Billable/Reportable [MU] if the exam is billable and should be documented as a reportable exam for meaningful use measures.
      Deselect Exam is Billable/Reportable [MU] if you are creating an exam record for a phone call, desk chart, contact lens follow-up, etc., so that the patient notes are not documented as an office visit/patient encounter for meaningful use measures.

      I hope that helps.

      1. So, we should leave this box checked for all full exams and deselect the check box for phone calls, desk charts, contact lens checks, etc?

  13. If a patient refuses to give height and/or weight, can we record ‘Not reported’ and still satisfy the requirement?

    1. Heather,

      During attestation the answers for this are numbers and percentages, so “not reported” won’t work. However, the successful fulfillment of this objective is 50% of unique patients. That would be more than enough room to provide for those few who “refuse”. Also, you can exclude this whole measure if you feel that it’s not relevant to your practice.

      James Kirchner, OD
      Chief Professional Officer, Eyefinity

      1. Dr. Kircher,

        In an audit situation on Core Measure #8 how would you recommend responding to why the three vital signs have no relevance to the scope of practice(If we chose to exempt this measure)? We take blood pressure on any patients w/ signs of hypertensive retinopathy but not on every patient. Just wanted to make sure the wording was correct. Thanks!

    1. Matt,

      Each eligible provider must evaluate the relevance of core objective #8, vital signs, to his or her practice. Many optometrists are now collecting vital signs (height, weight, BP) because they feel that it is relevant to the full-scope of optometry and and supports optometry’s role in comprehensive health care. Many others are using the exclusion for the objective and, therefore, still providing meaningful use for that measure. It is up to you to decide. There is no right or wrong with this one.

      James Kirchner, OD
      Chief Professional Officer, Eyefinity

  14. I am concerned about one item of meaningful use. It says I must exchange information by sending a test CCR or CCD to another practitioner. I do not know of any other practitoner with a certified EHR that can receive the information from Microsoft Vault. Can I send a maded up CCR to someone at Eyefinity and receive a confirmation to meet the requirement?

    1. Rob –

      All that the requirement states is to test the functionality. A doctor can create the CCR, send it electronically to another provider, have that provider open the document and store it on their system. The other doctor doesn’t have to have a Certified system, just being able to receive the CCR and open/save it is enough. Then the sending doctor can say that he/she did the test when they do the attestation.

      -James Kirchner, OD
      Chief Professional Officer of Eyefinity

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