2014 Meaningful Use Attestation Tips

With 2014 all wrapped up many providers are eager to attest for Meaningful Use under the EHR Incentive Program  and our phone lines are ringing with calls from managers and providers as they begin filling out their attestations online. We’ve put together the following list of reminders and best practices, that when followed can make attestation a breeze!

Prior to attesting AZCOMP recommends that Eligible Providers:

1. Run the Performance Metrics Report for the Stage and Reporting Period you will be attesting for. In 2014, unless it is your first year attesting for meaningful use you will select one quarter of the year as your reporting period (Jan-Mar, Apr-Jun, Jul-Sept, Oct-Dec). Eligible Providers attesting for the first time in 2014 can select any continuous 90 day reporting period.If you are unsure which Stage you are attesting for this year we recommend first determining which Stage you were originally scheduled to attest to by completing the EHR Participation Timeline Tool. Once you know which Stage you were scheduled to attest for this year, if you were unable to fully implement 2014 CEHRT and will be attesting under the Flexibility Rule you can complete the Flexibility Rule Decision Tool to determine what your options are for attesting in 2014.
2. Run the Clinical Quality Measures (CQM) Report for the reporting period you are attesting for.
   Please note that if you are attesting under the flexibility rule for Stage 1 under the 2013 definition, you must have a copy of the CQM report run from the 2011 Certified Edition of the EHR (v9.5.2). If you were on the 2011 Certified Edition of the EHR for a portion of the reporting period and then upgraded to the 2014 Certified Edition during the reporting period, in order to attest under Stage 1 2013 Definitions you must have a copy of the CQM report for the portion of the reporting period that the 2011 Certified Edition was in place. After upgrading to the 2014 Certified Edition you will only be able to run the CQM report required for Stage 1 2014 Definition and Stage 2. With the exception of those providers who may be attesting to Stage 1 2013 Definition using a combination of both the 2011 and 2014 Certified versions of the EHR during the reporting period, all other providers should run a CQM report for the same reporting period they ran the Performance Metrics report for (1 Quarter of the year, or a continuous 90 day reporting period for those providers attesting for the first time)For more information on CQMs and the Flexibility Rule we recommend reviewing pages 52918-52919 of the Final Rule.AZCOMP also recommends that if you are reporting zeros for any of the CQMs that you run the report for ALL available measures. The complete report will be useful in case you are audited and need to show which measures were available to you in the EMR at the time, and that all additional measures that you chose not to report also had zeros.
3. Complete the applicable Attestation Worksheet for the stage you will be attesting for. This will help ensure that you have gathered all the information you need in order to attest. The worksheets ask the same questions you will get when you are attesting and completed worksheets can be saved for future reference. The worksheet will also help you review the Yes/No measures to verify that you have supporting documentation. We recommend keeping supporting documentation for any of the measures you are claiming exemption from as well.
4. Complete the Attestation Calculator for the Stage you are attesting for. The attestation calculator will simulate an actual attestation and let you know if you will pass or fail the attestation with the data you have entered. Please note that the attestation calculator does not include CQM reporting in the simulation, this will be required when you actually attest.
5. Reference the Attestation Guide. CMS has put together a step-by-step walk through of the attestation process with valuable tip as a tool for all providers, including a guide on how to attest using the flexibility rule:  CEHRT Flexibility Attestation Guide

Don’t forget to Update Attestation Information:

• Login to the attestation site at https://ehrincentives.cms.gov/hitech/login.action
  If you have forgotten your user name and password please contact the EHR Incentive Program Information Center at 888-734-6433 / TTY 888-734-6563
• Go to the Attestation Tab or Topic, find program year 2014 in the attestation selection section and hit to “Attest” button in the far right column. (If you have already started your attestation for 2014 it should show a status of “In Progress” and the button will say “Modify” instead of “Attest”)

• Verify that you have updated the Attestation Information section with the correct EHR Certification Number. (We have seen it defaulting to the previous attestation years EHR Certification Number which may or may not be correct if you upgraded before or during your reporting period.)

You can locate your EHR Certification number by going to the “How do I find my EHR Certification Number hyperlink which will take you to the Certified Health Record IT Product List Website.

The Certified Health Record IT Product List Website will ask you which edition of the EHR you are attesting with. You should select the Edition or combination of Editions that you were using during the reporting period.

Tip when searching for your product, do not hit the “Enter” button on your keyboard after typing the product name as it will not produce any results. You must hit the “Search” button to see results.

Once you locate the product used during the reporting period, click the “Add to Cart” button.

If only one product was used during the reporting period, and that product is visible in the cart then click the “Get CMS EHR Certification ID” to view the certification number. If you upgraded during your reporting period you will need to add both products to the cart before generating the CMS Certification ID. You can an additional product version by clicking on one of the return to search options in the lower right corner.

Once the Certification ID is displayed we recommend copying and pasting it into the Attestation Information window. This will reduce the likelihood of human error that could result from manually typing in the code. We also recommend printing a copy of the certification ID page to retain with your Attestation records.

The following table is the list of codes that were obtained for McKesson EHR products through the Certified Health Record IT Product List Website and can be used to verify the Attestation Information you are entering.

Once you have entered in the EHR Certification Number you will be asked to select your reporting period for 2014.

Depending on the Stage you are scheduled for and the EHR product version you chose, the Stage Selection section may vary.

We have included the most common example below, which is for providers that were scheduled for Stage 2 in 2014 and were using the 2014 Certified version of the EHR during the entire reporting period. These providers will be asked whether or not they will be attesting for Stage 2 or Stage 1. If Stage 1 is selected they will be asked to confirm that they are attesting for Stage 1 due to the fact that they were unable to fully implement the 2014 CERT due to delays in availability (meaning they qualify to use the flexibility rule).

For more information on qualifying for the options under the flexibility rule view our Meaningful Use 911 Webinar.

Things to Watch for When Entering Attestation Numbers:

• Both Core and Menu Objectives require providers to exceed the minimum thresholds in order to pass. (If the objective requires 50% then provider must report 51% or higher)
• Pay attention to whether or not you are keying the numerators and denominators in the correct fields, a simple check is to make sure you haven’t keyed in a numerators that is larger than a denominator can help you avoid a costly mistake.
• Verify that all measures that ask for the number unique patient seen during the reporting period, that do not have any other requirements to them such as patient’s age, minimum number of visits, etc), all have matching denominators. Note that reporting denominators that are inconsistent for “Unique patient” measures can be a red flag for auditors. Here is a list of the measures that should produce the same denominator:Stage 1:
  – Maintain Problem List
  – Maintain Active Medication List
  – Maintain Allergy List
  – Record Demographics
  – Patient Electronic Access
  – Patient EducationStage 2:
  – Record Demographics
  – Patient Electronic Access (for both measures 1 & 2)
  – Secure Messaging
  – Electronic Notes
  – Structured Family History
• If any of the reports look off Please contact support immediately!
  (Ex: denominators higher than numerators, denominators that do not match for unique patient count) A number of patches have been released the past few months and if you have not kept your software up to date it is possible that report may be off as a result.

Review Menu Objective Requirements for 2014

If reporting for Stage 1 CMS has recently acknowledged a flaw in the attestation system regarding reporting menu objectives under Stage 1, this may or may not apply to all providers. Please see the highlighted area below for further details. (This information that was provided by CMS in an email communication on January 15, 2015)

Guidance on Reporting Menu Objectives

Eligible professionals participating in Stage 1 of the EHR Incentive Programs are required to report on a total of 5 meaningful use objectives from the menu set of 9 objectives. When selecting five objectives from the menu set, eligible professionals must choose at least one option from the public health menu set.

If an eligible professional is able to meet the measure of one of the public health menu objectives but can be excluded from the other, the eligible professional should select and report on the public health menu objective he or she is able to meet.

If an eligible professional can be excluded from both public health menu objectives, the eligible professional may meet the menu requirement one of two ways:

1. Claim an exclusion from only one public health objective and report on four additional menu objectives from outside the public health menu set.
2. Report on five menu objectives from outside the public health menu set

Eligible professionals participating in Stage 2 are required to report 3 meaningful use objectives from the menu set of 6.

We encourage eligible professionals to select menu objectives that are relevant to their scope of practice, and claim an exclusion for a menu objective only in cases where there are no remaining menu objectives for which they qualify or if there are no remaining menu objectives that are relevant to their scope of practice.

For example, we hope that eligible professionals will report on 5 measures, if there are 5 measures that are relevant to their scope of practice and for which they can report data, even if they qualify for exclusions in the other objectives.

The Registration and Attestation System may prompt an eligible professional to report on additional measures if he or she claims an exclusion. This is because starting in 2014, the exclusion criteria will no longer count as reporting a meaningful use objective from the menu set. An eligible professional must meet the measure criteria for the objectives or report on all of the menu set objectives through a combination of meeting the exclusions and meeting the measures.

However, some eligible professionals who elect option 1 above may be asked to report on non-public health measures when they claim that exclusion in the Attestation System. These providers should document this issue for their records, and then claim the exclusion for the remaining measures in order to allow the system to accept their attestation.

Retain Supporting Documentation

Remember to retain supporting documentation for 6 year! We recommend keeping electronic copies of all reports and screen shots on your server where you know it is being backed up and will be easily retrieved in case of an audit.

Disclaimer: AZCOMP Technologies, Inc, (AZCOMP) is providing this material as an informational reference for eligible professionals. Although every reasonable effort has been made to assure the accuracy of the information within these pages at the time of posting, the EHR Incentive program is constantly changing, and it is the responsibility of each provider to remain abreast of the EHR Incentive program requirements.