Another Oops in MU Rule Text?

It's a good thing the ink is still drying on the final rule text for meaningful use.  Robin Raiford is an extremetly detail oriented person who also does some of the best chartography making send of meaningful use, standards, and all the rest that I know.  Robin reports in a widely distributed e-mail that:

While gathering data for the poster and validating the dots were all correct – I have found 7 errors in Table 3 of the CMS final rule in the table layout.


If you read the text close, they kind of jump right out at you. In table 3 there are 7 items that have “unique patient” in the description of the measure and they are grouped in that portion of the table under “Measures with a Denominator of Unique Patients Regardless of Whether the Patient’s Records Are Maintained Using Certified EHR Technology”, rather than with the “unique patients” denominator items . My dots in the poster were not lining up exactly – and I discovered I had placed them using the text – not the table. So that is how I found it.

I have passed this on to the Co-chairs of HIT Policy and HIT Standards and John Halamka has passed on to Tony Trenkle at CMS for comment. So either there are two meanings for “unique” or something is in the wrong place in Table 3. So stay tuned how CMS resolves or makes it know their intent. Since one has Denominator of UNIQUE PATIENTS Regardless of Whether the Patient’s Records Are Maintained Using Certified EHR Technology and the other Measures with a Denominator of Based on Counting ACTIONS for Patients whose Records are Maintained Using Certified EHR Technology Stage 1 Objectives – this has HUGE implications for the ED and those 11 measure that include POS 23 and POS 21.

As I learn more, I'll post it here.  Thanks Robin, and keep up the goodGREAT work!

     Keith