ASCs were not addressed in HITECH, so while there is a CEHRT for hospitals and one for physician offices, there is no CEHRT for ASCs. It is unlikely that ASCs will have the necessary certified EHRs in place in order to meet the 50 percent requirement by the current deadline because the purchase of EHRs by ASCs has not been subsidized like it has for physician offices and hospitals and the certification standards were developed without ASCs in mind.
Physicians who operate in ASCs, however, are still EPs, and must meet the meaningful use requirements. If a physician were to see a patient in an office setting, perform the patient’s surgery in an ASC and conduct a follow-up appointment in an office, two of the three patient encounters (67 percent) would take place in a setting equipped with a CEHRT (assuming that the physician office is equipped as required). If most of the physician’s cases were managed like this, meaningful use requirements would be met. Physicians who work primarily in an ASC setting, however, might be subject to penalties. In addition, more physicians could be affected if CMS increases this threshold in the future.