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Meaningful Use in 2016

Don’t miss out on what’s happening in 2016 with Meaningful Use!

Providers that wait until 2016 to review what they need to be doing for meaningful use in 2016 may miss the mark!

Remember that unless you are in your first year of participating in the EHR Incentive Program (Meaningful Use), providers will be required to attest for the entire calendar year of 2016. Since there are certain measures that require providers to attest that the functionality was enabled the entire reporting period, there is a high risk to missing the mark. It’s all or none when it comes to meaningful use, therefore we are encouraging providers to take time to review the changes and make sure you are on track well before January 1st. Providers that wait may find it is too late!

Get Started before January 1st!

A great resource to review is this recently released overview document of what has changed in the program and what is REQUIRED in 2016:

Providers are also encouraged to keep supporting documentation at the beginning of the reporting period (January 1st) for yes/no attestation measures, for more information review the Supporting Documentation for Audit Tipsheet from CMS.

Tell me more…

Let us help you along the way. We have many resources available on our blog to help answer questions about the EHR Incentive Program and Meaningful Use. Click here to find previous articles.

Need Any Assistance? Our Trainers Can Help.

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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 Medicare/Medicaid programs are constantly changing, and it is the sole responsibility of each provider to remain abreast of  program requirements by consulting the authorities and documentation found directly at http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/index.html

Important Update on CQM Reporting for 2015

Please take note of the changes to Clinical Quality Measure (CQM) Reporting for 2015:

Providers participating in the EHR Incentive Program (Meaningful Use)  or electronically reporting for the Physician Quality Reporting System (PQRS) Program are required to use the 2014 eCQM Specifications for their 2015 calendar year reporting.

Run The Updater On Your Server

This important update is to notify users that McKesson has now released a software patch on 11/4/2015 for Medisoft Clinical, LytecMD, and Practice Partner that will update the CQM reporting tool from the 2013 eCQM specifications to the new 2014 eCQM Specifications. Practices must run the updater on the server to apply the patch.
If there are any questions on running this update, feel free to contact our Support department for further assistance.

Review Your Selected Reporting Measures

Depending on the specific quality measures the provider is reporting, installing the software patch alone may not be enough as a number of the measures require configuration and workflow training in order to ensure the data is being captured in a manner that the report can read the data.
We are advising all providers to both update the software and review the measures they have selected for any changes to the configuration and workflow. A new user guide was released in conjunction with this update which includes all of the details on configuration and reporting.
Access and Download the guide here: CQM Report User’s Guide 2015

Need Any Assistance? Our Trainers Can Help.

If you need assistance with configuration, implementation and training on CQMs we recommend working one-on-one with one of our Certified Trainers. Call us at (888) 799-4777 to get set up with your training.

Submit Your Comments on Stage 3 & 2015 Edition Health Information Technology Certification Criteria NPRMs

Check out this eHealth News Update from the Centers for Medicare & Medicaid Services (CMS)

Stage 3 NPRM Comment Period Now Open: Submit by May 29

CMS and ONC invite the public to submit comments on the recently released notices of proposed rulemaking (NPRMs) on Stage 3 requirements and EHR technology certified to the 2015 Edition for the Medicare and Medicaid EHR Incentive Programs. Comments must be received by May 29 to be considered.

About the NPRMs
The CMS NPRM specifies the Stage 3 requirements for eligible professionals, eligible hospitals, and critical access hospitals in the EHR Incentive Programs. ONC’s proposed rule outlines the certification and standards to help providers meet the proposed Stage 3 requirements with EHR technology certified to the 2015 Edition.

If finalized, the rules would allow providers more flexibility for reporting by:

  • Establishing a single, aligned reporting period for providers based on the calendar year
  • Aligning quality data for reporting via a single submission method for multiple CMS programs
  • Simplifying meaningful use reporting requirements to eight objectives that focus on advanced use of EHR technology and quality improvement

The Stage 3 proposed rule’s scope is limited to the requirements and criteria for meaningful use in 2017 and beyond. CMS is pursuing additional changes to meaningful use beginning in 2015 through separate rulemaking.

How to Submit Comments
The public can submit comments in several ways, including via electronic submission or mail:

  1. Electronically
  2. By regular mail
  3. By express or overnight mail
  4. By hand or courier

View the Stage 3 and 2015 Edition Health Information Technology Certification Criteria proposed rules online for more information. Submissions must be received by 11:59pm ET on May 29, 2015 in order to be considered.

For More Information
For more information on the Stage 3 and 2015 Edition Certification Criteria proposed rules, review the press release and fact sheet

CQM News Flash for Medisoft Clinical, LytecMD, & Practice Partner Users!

McKesson released the following letter on January 16, 2015:

This letter provides information regarding the current capability of Practice Partner® v11.0 as it relates to submission of the following reports:

  • Physician Quality Reporting System (PQRS) 
  • Electronic Clinical Quality Measures (eCQM) reports 
  • Comprehensive Primary Care Initiative (CPCI) reports

McKesson certified Practice Partner v11.0 with the Office of the National Coordinator for HealthCare IT (ONC) is using a tool called Cypress. Cypress is one of the rigorous and repeatable testing tools used by ONC to certify Electronic Health Records (EHRs) and EHR modules in calculating performance metric reports and Clinical Quality Measures (CQMs) for Meaningful Use (MU) Stage 2.

The Centers for Medicare & Medicaid Services (CMS) recently indicated the Quality Reporting Document Architecture (QRDA) file format certified previously with Cypress is not the layout they accept. The QRDA format that CMS accepts is the combined format for CQM, CPCI and PQRS. Therefore, McKesson needs to make modifications to Practice Partner v11.0 to allow for the required format that CMS will accept for PQRS reporting.

McKesson is working diligently with CMS to understand the changes needed in Practice Partner v11.0 in order to provide our customers the ability to report on PQRS measures via CEHRT. To date, we have successfully registered for QualityNet and we are conducting focused testing and certification on the QRDA file format to help ensure that the changes made meet CMS requirements.

IMPORTANT NOTE: Until this testing is complete, customers will not be able to submit CQM data electronically.

There are 64 possible Clinical Quality Measure (CQM) reports required for Stage 2 certification. These same measures are valid for PQRS submission. Practice Partner currently provides 38 of these reports, with another five that will be released in January 2015, bringing the total number to 43. These 43 measures should cover the majority of primary care and specialty requirements. Additional measures will be considered in the future road map based on request, but currently there are no additional CQM reports slated to be added.

For practices participating in the CPCI program, please watch for future notification on how to attest manually for this incentive program.

We will continue to provide updates with our progress as it relates to the above information.

Sincerely,

Tom Reinecke
Director – Product Management
Business Performance Services

———————————————–

What does this mean for Medisoft Clinical / LytecMD / Practice Partner Users?

Users that are participating in the EHR Incentive Program can meet the requirements for Meaningful Use by selecting to report CQM data through attestation. This will satisfy the requirements for Meaningful Use, however it will not satisfy the requirements for the PQRS program.

With this announcement it is imperative that Practices that have not already submitted PQRS data for 2014 make proper arrangements to do so.

Facts about PQRS:

  • Providers can earn a Bonus payment of 0.5% of their total estimated Medicare Part B allowed charges by reporting PQRS data for 2014.
  • There is a 2% payment adjustment/penalty that will be deducted from all Medicare Part B payments for services provided in 2016 if providers do not satisfactorily report PQRS for 2014.
  • The deadline to submit PQRS data for 2014 is February 28, 2015.

There are several ways to report PQRS data for 2014 including:

  1. Claims Based Reporting:
    Requires appropriate G codes for 9 individual measures to have been billed on Medicare Part B Claims for 50% of applicable patients for the entire calendar year of 2014
  2. Qualified Registry Reporting: 
    Option A: Choose 1 Measure group to report 20 applicable patients
    – 12 Month OR 6 Month Reporting Period)
    – At least 11 patients must be Medicare patients
    Option B: Choose 9 Individual Measures aross 3 NQS Domains for at least 50% of Medicare patients to whom the individual measures apply.
    – 12 Month Reporting Period
    List of 2014 Qualified Registries
  3. Direct EHR Reporting:
    Report on 9 Individual Measures across 3 NQS Domains for applicable patients for a 12 Month Reporting Period.
    – In 2014 CMS is allowing providers to single report quality measures to PQRS for the entire year (12 Month reporting period) and have it qualify for the CQM requirement under Meaningful Use. However, because the 2014 CEHRT versions of Medisoft Clinical/LytecMD/Practice Partner (v11) were not released until after the start of the year, and due to the fact that many of the measures require configuration or changes to documentation in order to capture the data in a manner that will produce numbers on the CQM reports, it is unlikely that any providers will have a full year’s worth of data in their CQM reports. In addition, the announcement cited above from McKesson confirms that direct EHR Reporting is not available at this time.
  4. EHR Reporting via Data Submission Vendor:
    Report on 9 Individual Measures across 3 NQS Domains for applicable patients for a 12 Month Reporting Period.
    – McKesson is not currently partnered with any Data Submission Vendors, however, there may be Data Submission Vendors that are compatible with Medisoft Clinical/LytecMD/Practice Partner as a third party solution. Providers are responsible for working directly with third party vendors to report via this method.
    – Data Submission Vendors require the applicable data to be recorded in a structured manner for the entire 12 month reporting period in order for them to accurately export and report the data on the providers behalf.
  5. Qualified Clinical Data Registry (QCDR):
    Report on 9 Individual Measures across 3 NQS Domains for applicable patients for a 12 Month Reporting Period.
    – McKesson is not currently partnered with any QCDRs, however there may be QCDRs that are compatible with Medisoft Clinical/Lytec MD/Practice Partner as a third party solution. Providers are responsible for working directly with third party vendors to report via this method. 2014 Certified QCDRs List

For practices that did not report PQRS data through claims in 2014 we are recommending Qualified Registry Reporting. While AZCOMP has no direct experience with any of the Registries, and therefore cannot endorse any specific registry, we have found sites such as MDInteractive.com that have made the process for reporting PQRS simple. For example, if providers qualify to report under a measure group then MDInteractive.com has a worksheet (usually 1-2 pages with 9 or fewer questions) that only need to be filled out for a total of 20 applicable patients (11 must be Medicare). We have heard that the entire process generally takes an office 4-6 hours to identify the patients, fill out the worksheets and enter the information into the registry. For specific questions regarding registry reporting please contact the registry of your choice directly as AZCOMP does not directly support registry reporting.

For Questions Regarding the PQRS program contact the QualityNet Help Desk

  • Available Monday – Friday; 7:00 AM–7:00 PM CST
  • General CMS Physician Quality Reporting System Incentive Program information
  • Portal password issues
  • Feedback report availability and access
  • PQRI-IACS registration questions
  • PQRI-IACS login issues

Phone: 1-866-288-8912

TTY: 1-877-715-6222

Email: Qnetsupport@hcqis.org

 

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.

EHR Reporting for 2014 Ends Today!

2014 Reporting Ends for Eligible Professionals on December 31, 2014; Time to Prepare for Attestation

This is a repost from a CMS update sent out yesterday (December 30, 2014).

CMS reminds eligible professionals participating in the Electronic Health Record (EHR) Incentive Programs that December 31, 2014 marks the end of the 2014 calendar year (CY) and the end of the last 2014 EHR reporting period.

Attestation Deadline

If you are an eligible professional participating in the Medicare EHR Incentive Program, you have until February 28, 2015 to attest to demonstrating meaningful use of the data collected during your EHR reporting period for the 2014 calendar year.  If you are participating in the Medicaid EHR Incentive Program, please refer to your state’s deadlines for attestation information.

The CMS Attestation System is open and fully operational, and includes the 2014 Certified EHR Technology (CEHRT) Flexibility Rule options.  Medicare eligible professionals can attest any time to 2014 data until 11:59 pm ET on February 28, 2015.

Reminder: You must attest to demonstrating meaningful use every year to receive an incentive and avoid a Medicare payment adjustment.

Payment Adjustments

Payment adjustments will be applied beginning January 1, 2015 for Medicare eligible professionals that did not successfully demonstrate meaningful use in 2013 (or 2014 for first-time participants) and did not receive a 2015 hardship exception.

Medicare eligible professionals that did not successfully demonstrate meaningful use in 2014 and do not receive a 2016 hardship exception will have payment adjustments applied beginning January 1, 2016.  The application period will open in early january 2015.

If you are eligible to participate in both the Medicare and Medicaid EHR Incentive Programs, you MUST demonstrate meaningful use to avoid the payment adjustments.  You may demonstrate meaningful use under either Medicare or Medicaid.

If you are only eligible to participate in the Medicaid EHR Incentive Program, you are not subject to these payment adjustments.

Attestation Resources

  • Stage 1 Eligible Professionals Meaningful Use Table of Contents (2014 definition)
  • Stage 2 Eligible Professionals Meaningful Use Table of Contents
  • 2014 Stage 1 Attestation User Guide for Eligible Professionals
  • 2013 Stage 1 Attestation User Guide for Eligible Professionals
  • Stage 2 Attestation user Guide for Eligible Professionals
  • CEHRT Flexibility Attestation Guide

Note: January 1, 2015 marks the start of Stage 2 for eligible professionals who have already completed at least two years of Stage 1.

Meaningful Use Well Check

Time for your end of the year Meaningful Use Well Check 🙂

Meaningful Use Well CheckAs 2014 is drawing to a close the window of opportunity is also closing for meeting Meaningful Use requirements in 2014.  This year we have seen changes to the EHR Incentive Program as well as updates released for the software.  Missing any of these changes could put your practice in jeopardy of not qualifying for meaningful use.  Please take a few moments to review some of the basics to make sure your practice is still on track to successfully attesting for 2014!

Review the Flexibility Rule:

CMS is allowing practices that have not had sufficient time to fully implement the 2014 Certified Electronic Health Records Technology (CEHRT), due to delays in availability, the options to attest using 2011 CEHRT. If you qualify for the CEHRT Options under the flexibility rule, determine which Stage you will attest for this year:

  • Stage 1 2013 Definition
  • Stage 1 2014 Definition
  • Stage 2

For an overview of how to determine if you are eligible for the flexibility rule review: Meaningful Use 911 Webinar

Run your Performance Metric Reports

Run your performance metric reports regularly to ensure you are meeting the thresholds! Remember in v11 you can use the drill down capability in the reports to identify which patients are not included in your numerators. In many cases it will not be too late to make corrections in the patient’s chart to ensure that the data is captured properly so that it can be reflected in your performance metrics report.

Review Menu Objectives

Review Menu objectives to ensure you have the right number to report! CMS is no longer allowing users to claim an exemption and have that count towards their total required menu objectives. If you have claimed an exemption in the past make sure you have selected an additional menu objective to attest to this year. For providers in Stage 1 that may find they are short a measure, it is not too late to send out patient reminders and we have a free webinar you can watch to teach you how to do it!

Patient Reminders Webinar

Providers attesting for Stage 1 2014 Definition or Stage 2 must have a patient portal (Webview)

For more information on changes effective this year, view the following CMS document: 2014 Changes Tipsheet

Review CQM Reports

Providers attesting to Stage 1 2014 Definition or Stage 2 must report 9 CQMs this year. Many CQMs require configuration. Some issues have been identified with the CQM reports in v11, please make sure you are on the latest update of the report so you can ensure you are getting the most accurate numbers, contact support right away if you need updates.

For more information review our recent blog post: New Clinical Quality Measures (CQM) Manual Released!

Ensure that you have supporting documentation for the Yes/No Attestation measures

Ensure that you have supporting documentation for the Yes/No Attestation measures. Not all measures have a threshold and therefore there is no performance metric the system can produce on a report to indicate whether the provider met the measure. CMS recommends keeping supporting documentation for each of the Yes/No attestation measures that the provider attests to. Providers should keep copied of supporting documentation for 6 years post attestation in case of an audit. Yes/No Measures include:

ObjectiveAudit ValidationRecommended Supporting Documentation
Drug-Drug/Drug-Allergy Interaction ChecksFunctionality is available, enabled, and active in the system for the duration of the EHR reporting period.One or more screenshots from the certified EHR system that are dated during the EHR reporting period selected for attestation.
Clinical Decision SupportFunctionality is available, enabled, and active in the system for the duration of the EHR reporting period.One or more screenshots from the certified EHR system that are dated during the EHR reporting period selected for attestation.
Protect Electronic Health InformationSecurity risk analysis of the certified EHR technology was performed prior to the end of the reporting yearCopy of a completed security risk analysis that was conducted during the calendar year the provider is attesting for. It can be performed outside of the reporting period but must be completed no earlier than the first of the year, and no later than the last day of the year.
Drug Formulary ChecksFunctionality is available, enabled, and active in the system for the duration of the EHR reporting period.One or more screenshots from the certified EHR system that are dated during the EHR reporting period selected for attestation.
Generate Lists of Patients by Specific ConditionsOne report listing patients of the provider with a specific condition.Report from the certified EHR system that is dated during the EHR reporting period selected for attestation.
Immunization Registries·Data Submission, and Syndromic Surveillance Data SubmissionOne test of certified EHR technology’s capacity to submit electronic data and follow-up submission if the test is successful.
  • Dated screenshots from the EHR system that document a test submission to the registry or public health agency (successful or unsuccessful). Should include evidence to support that it was generated for that provider’s system (e.g., identified by National Provider Identifier (NPI), CMS Certification Number (CCN), provider name, practice name, etc.).
  • A dated record of successful or unsuccessful electronic transmission (e.g, screenshot from another system, etc.). Should include evidence to support that it was generated for that provider (e.g., identified by National Provider Identifier (NPI), CMS Certification Number (CCN), provider name, practice name, etc.).
  • Letter or email from registry or public health agency confirming the receipt (or failure of receipt) of the submitted data, including the date of the submission, name of parties involved, and whether the test was successful.
ExclusionsDocumentation to support each exclusion to a measure claimed bythe provider.Report from the certified EHR system that shows a zero denominator for the measure or otherwise documents that the provider qualifies for the exclusion.

Preparing for Attestation

A few tools that can help you prepare for your attestation are the CMS attestation worksheets and the attestation calculators that allow you to practice attesting to see if you are passing before submitting your actual attestation:

Stage WorksheetCalculator
Stage 1 2013 DefinitionAttestation Worksheet Stage 1 (2013)Stage 1 Calculator
Stage 1 2014 DefinitionAttestation Worksheet Stage 1 (2014)Stage 1 Calculator
Stage 2Attestation Worksheet Stage 2Stage 2 Calculator

Look Ahead!

Just a reminder, as it stands today the reporting period for 2015 is a full calendar year for all providers that have previously participated in the EHR Incentive program. All providers are required to be on the 2014 CERT for the entire reporting period. If you are scheduled for Stage 2 in 2015 please ensure that you have taken proper steps to configure your EHR for the new objectives and requirements.

We are here to help!

If you need assistance with any of the checklist items above please contact us immediately to schedule time with a trainer. The timeframe is limited and schedules are filling up so do not delay!

We know the amount of work each of you have put into making changes to your practice in order to meet meaningful use objectives, and congratulate each of you for taking the steps to ensure your patients are receiving the BEST care!

 

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.

New Clinical Quality Measures (CQM) Manual Released!

An updated Medisoft Clinical/LytecMD/Practice Partner Clinical Quality Measures (CQM) User’s Manual has been released!

The manual includes changes to configuration requirements for some of the measures as well as details on where the reports pull information from in order to calculate the denominators and numerators. CQM Report User’s Guide Nov 2014

Who should review the new CQM manual?

  • Providers that are participating in the EHR Incentive Program in 2014 who will be attesting under Stage 1 2014 Objectives
  • Providers who will be reporting Stage 2 Objectives in 2014
  • All providers that are participating in the EHR Incentive Program in 2015 (Remember unless 2015 is your first year to participate the 2015 reporting period is currently scheduled as a full calendar year. This means providers need to be ready to capture CQM data starting January 1, 2015)

As a reminder, providers attesting Stage 1 2014 Objectives, or Stage 2 for 2014 and in 2015 will be required to report a total of 9 measures covering at least 2 of the National Quality Strategy domains. Under 2014 rules providers are no longer required to report a core set of measures, however CMS has outlined a recommended set of 9 Adult Measures, and 9 Pediatric Measures. For detailed information please visit the EHR Incentive Website: http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/2014_ClinicalQualityMeasures.html

No Threshold Requirement for CQM Reporting

For providers that are unable to find 9 out of the available measures in their CEHRT that apply to their specialty, CMS has stated: “We understand cases may exist where an EP may not find a full set of CQMs where they have data for both the numerator and denominator. We remind providers that they may submit a zero as the denominator for a CQM if that is the resulting calculation displayed by their EHR” https://www.federalregister.gov/articles/2014/09/04/2014-21021/medicare-and-medicaid-programs-modifications-to-the-medicare-and-medicaid-electronic-health-record

CQM Reporting in 2014 using the Flexibility Rule

Under the new Flexibility Rule providers may be eligible for the following options for 2014 Reporting:

CEHRT Options 2014

According to the Final Rule, Providers must attest to the required set of objectives and measures applicable for the CEHRT option they choose, as well as the CQMs that relate to that option.

CQM Reporting Options Flexibility Rule

If a provider chooses the 2013 Stage 1 objectives and measures they must attest to the CQMs using the reporting requirements specified for 2013. (6 total measures comprising of 3 core/alternate core, and 3 additional measures) The reports for 2013 CQMs are only available if the provider is running Medisoft Clinical/LytecMD/Practice Partner v9.5.2.

CQM Comparison

According to the final rule, “If a provider elects to use a combination of 2011 Edition and 2014 Edition CEHRT and chooses to attest to the 2013 Stage 1 objectives and measures for its EHR reporting period in 2014, the provider would be required to report CQMs by attestation using the same measure sets and reporting criteria outlined earlier for providers who elect to use only 2011 Edition CEHRT for the EHR reporting period in 2014. Because of the differences in how CQMs are calculated and tested between the 2011 and the 2014 Editions of CEHRT, we further proposed that a provider may attest to data for the CQMs derived exclusively from the 2011 Edition CEHRT for the portion of the reporting period in which 2011 Edition CEHRT was in place.”

Since the 2013 CQM Reports are only available in Medisoft Clinical/LytecMD/Practice Partner v9.5.2 providers are reminded that they should run the CQM report PRIOR to upgrading with a date range equal to the first day of the reporting period up to the date of the upgrade. Providers are advised to maintain copies of the report as supporting documentation for their attestation. Once the upgrade to v11 has been completed the practice will not have access to run the 2013 CQM report again.

EHR Incentive Program CQM Reporting Options for Eligible Professionals in 2014 Include:

    • Option 1: Attest to CQMs through the EHR Registration & Attestation System (Reporting Period: 90 day period for first time participants, all others must select any 3 month quarter.)
    • Option 2: eReport CQMs through Physician Quality Reporting System (PQRS) Portal (Reporting Period: Entire calendar year)

Because the 2014 CEHRT versions of Medisoft Clinical/LytecMD/Practice Partner (v11) were not released until after the start of the year, and due to the fact that many of the measures require configuration or changes to documentation in order to capture the data in a manner that will produce numbers on the CQM reports, it is unlikely that any providers will have a full year’s worth of data in their CQM reports. In addition v11 is not currently compatible with PQRS direct EHR reporting requirements. Therefore, participants of the EHR Incentive program should report their numbers for their 3-Month quarter/reporting period in 2014 through attestation. We further recommend reporting PQRS data through a qualified registry. For more information on PQRS registry reporting visit: http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/Downloads/2014_PQRS_Registry_Made_Simple_F01-08-2014.pdf

For assistance with configuration or training please contact us to schedule some one-on-one time with a Certified Trainer!

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 CMS programs are constantly changing, and it is the responsibility of each provider to remain abreast of the CMS program requirements.

Meaningful Use 911 Webinar Follow Up

Meaningful Use 911 Webinar Follow Up & Resources Used

Meaningful Use, EHR, Medisoft Clinical, Lytec MD, Practice Partner

Our Meaningful Use 911 event last Friday was packed with useful information on the latest changes to the EHR Incentive Program.

If you want to watch the replay you can click here to view it.

The Power Point is also available here: Meaningful Use 911

For those of you that want to take a deeper dive into all the resources that were used we’ve put together links to the source documents for each of the main topics that were reviewed in the webinar.

Flexibility Rule:

This includes all the details on the proposal that passed allowing more options for providers that could not fully implement 2014 Edition CEHRT for the EHR reporting period in 2014 due to delays in 2014 Edition CEHRT availability. During the webinar we discussed a number of questions and concerns that providers had regarding the flexibility rule as well as CMS’s responses. These comments and responses from CMS offer great insight and clarification and are well worth the read if you have any questions regarding what would qualify a provider to use the CEHRT Options in 2014.
https://www.federalregister.gov/articles/2014/09/04/2014-21021/medicare-and-medicaid-programs-modifications-to-the-medicare-and-medicaid-electronic-health-record

CMS 2014 CEHRT Flexibility Rule Decision Tool:

This tool provides an easy way to find out what options are available to you for reporting in 2014. Answer a few simple questions:
1) What CEHRT Edition are you currently using?
2) What stage of meaningful use are you scheduled to meet for the 2014 reporting period? (You can determine your scheduled Stage for 2014 by using the EHR Participation Timeline Tool)
After answering the questions it kicks out the options that are available to you for your 2014 Meaningful Use Reporting.
https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/CEHRT_Rule_DecisionTool.pdf

Stage 1 Changes Tipsheet:

For providers that have the option of either reporting Stage 1 2013 Definitions versus Stage 1 2014 Definitions it is important to understand what the differences are between the two options. The Stage 1 Changes Tipsheet provides an outline of the changes that went into effect in 2014 for all providers (such as no longer being permitted to count an exclusion toward the minimum of 5 menu objectives) as well as an outline of the differences between Stage 1 2013 and Stage 1 2014.
https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/stage1changestipsheet.pdf

McKesson Practice Partner/LytecMD/Medisoft Clinical 2014 Clinical Quality Measures User’s Guide November 2014:

The latest CQM User’s Guide for v11 was just released. The guide includes some new measures as well as modifications to some of the existing measures. In the webinar we discussed the importance of reviewing the guide to make sure that you are configured appropriately for the changes so that the reports will capture the information your practice is tracking. CQM Report User’s Guide Nov 2014

EHR Incentives Program Supporting Documentation for Audits:

The reality of Meaningful Use Audits is that they are a matter of “When” not “If”. In the webinar we discussed the importance of retaining supporting documentation for 6 years post-attestation and took a look at some of the recommendations for supporting documentation for the “Yes” objectives (objectives that have no denominator and numerator and therefore no report that providers can generate from the system to support their attestation.)
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/EHR_SupportingDocumentation_Audits.pdf

Clinical Decision Support Tipsheet:

Providers are required to implement “clinical decision support” in both Stage 1 and Stage 2 and to keep supporting documentation on how they met this objective. CMS has provided further clarification that clinical decision support is more than just “alerts”, and they have gone on to provide examples of clinical decision support is and what it is not.
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/ClinicalDecisionSupport_Tipsheet-.pdf

Guide to Privacy and Security of Health Information:

We discussed the Meaningful Use requirement to complete a Security Risk Analysis each year, reviewed the myths and facts, and what a security risk analysis entails as outlined in this guide. AZCOMP Technologies Inc. feels that it is in a providers best interest to do a thorough and professional risk analysis that will stand up to a compliance review. If your practice needs assistance on this measure please contact us for a referral to a proven Security Risk Analysis Professional!
http://www.healthit.gov/sites/default/files/pdf/privacy/privacy-and-security-guide.pdf

Recent Change to the Security Risk Analysis Requirement:

In the webinar we discussed the recent change that allows providers to complete a security risk analysis any time during the EHR reporting year, as opposed to the old requirement that stated that the provider must complete it before or during the reporting period for the reporting year. We believe this will offer more flexibility for providers that, in light of the new flexibility rule, may consider reporting for an earlier reporting period in 2014 that may not have completed their Security Risk Analysis yet. Under this change providers could still complete the risk analysis by the end of the year regardless of which quarter they choose to attest under. https://questions.cms.gov/faq.php?faqId=10754

EHR Program Incentives and Penalties:

During the webinar we reviewed the incentives for participation and penalties for non-participation in both the Medicare and Medicaid EHR Incentive Programs. Including the last years to begin participation.
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Basics.html

Payment Adjustments & Hardship Exceptions Tipsheet for Eligible Professionals:

This document discusses the scheduled penalties that begin in 2015, how they are calculated, who is eligible, and how to apply for hardship.
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/PaymentAdj_HardshipExcepTipSheetforEP.pdf

Re-Opened Hardship Application Period for 2015 Payment Adjustment:

Eligible professionals that have never met meaningful use before may apply during this reopened hardship exception application submission period if they were unable to fully implement 2014 Edition CEHRT due to delays in 2014 Edition CEHRT availability AND could not attest by the early attestation deadline for new participants. The new application deadline is November 30, 2014.

EHR Payment Adjustment Page: http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/PaymentAdj_Hardship.html

2015 HARDSHIP EXCEPTION APPLICATION – due 11/30/2014: http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/HardshipExtension_Application.pdf

We closed the webinar with a look ahead, reviewing what you should know about Stage 2:  

  • The reporting period for anyone scheduled for Stage 2 in 2015 is for the entire calendar year.
  • There is a proposal to adjust the 2015 reporting period to a 3 month reporting period.
    http://ellmers.house.gov/uploads/Flex-IT%20Act%20FINAL.pdf
  • As it stands today, Providers must be on a 2014 CEHRT prior to January 1, 2015.
  • Many of the new measures require configuration and training.
  • Some add-ons may be required and they take time to implement- don’t wait!
    (Webview, Lab Interfaces, Immunization Interfaces, direct email accounts)

http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/Stage2Overview_Tipsheet.pdf

Thanks again to everyone that joined us, and remember if you have further questions or would like a personal review of your Meaningful Use readiness please contact us to schedule a meaningful use assessment or one-on-one training today!

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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.

Hardship Exception Extension For Medicare EHR Incentive Program

Application Deadline for Hardships is Extended

ehr incentive program logoIn October, CMS reopened the submission period for hardship exception applications for eligible professionals and eligible hospitals to avoid the 2015 Medicare payment adjustments for not demonstrating meaningful use of certified EHR technology (CEHRT).

Eligible professionals that have never met meaningful use before may apply before November 30, 2014 if they were unable to fully implement 2014 Edition CEHRT due to delays in 2014 Edition CEHRT availability AND could not attest by the early attestation deadline for new participants.

Click here to learn more about the hardship exception application process and eligibility.

Click here for the actual hardship exception application.

2015 Physician Fee Schedule Final Rule

Recently there was a new rule made called The 2015 Physician Fee Schedule 2015 Final Rule. This rule included an Interim Final Rule with a request for public comment (IFC) related to the EHR Incentive Programs.  This IFC provisionally adopts changes to the regulatory language about hardship exceptions from the Medicare payment adjustment in the EHR Incentive Programs.

Part of the American Recovery and Reinvestment Act of 2009 (ARRA), Congress mandated payment adjustment penalties under Medicare for eligible professionals that are not meaningful users of CEHRT.  The ARRA also allows however, the Secretary to consider on a case-by-case basis, hardship exceptions for eligible professionals to avoid the payment adjustment penalties.

The language in this new rule makes changes to the ARRA regulation to support the extension of the hardship application period.  Comments are due by December 30, 2014, and more information will be available when the rule is published in the Federal Register later this month.

Additional Resources

You can review the 2015 Physician Fee Schedule Rule fact sheet for more information about the regulatory changes to the EHR Incentive Programs by clicking here.

You can get more information about the EHR Incentive Programs by visiting the CMS EHR website here.

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 Medicare/Medicaid programs are constantly changing, and it is the sole responsibility of each provider to remain abreast of  program requirements by consulting the authorities and documentation found directly at http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/index.html

 

Proposed CMS Rule Passes Providing Flexibility To Providers Attesting To Meaningful Use For 2014

Participants of the EHR Incentive Program whom have been struggling to deploy new software in order to meet requirements for both Stage 1 and Stage 2 that went into effect in 2014 may be able to breathe a big sigh of relief!

ehr incentive program logo

BACKGROUND: Because of the late release of the requirements for Stage 2, the changes made to Stage 1, and the mandate that all EHR vendors obtain 2014 Certification; the actual deployment 2014 Editions of Certified Electronic Health Record Technology (CEHRT) has been fraught with challenges. Numerous different parties voiced the following concerns to The Centers for Medicare and Medicaid Services (CMS):

  • Vendors were not given enough time to make the required coding changes and certify
  • The certification case load created a backlog of EHR products that were certified later than anticipated
  • Delays in the availability of 2014 CEHRT Editions shortened the time available to providers to implement upgrades, which includes not just the availability of the software but the time necessary to configure changes for patient safety, staff training, testing and workflow revisions in order to be prepared to demonstrate meaningful use.
  • Even when a certified version became “available” due to the high number of users needing to upgrade (Over 350,000 providers) many vendors reported a backlog of several months before providers could be scheduled for the upgrade.
  • Providers that upgrade to the 2014 CEHRT reported that they were still required to install software patches or make workflow changes that hindered their ability to fully implement the product.

In response to this feedback, CMS determined that it might be necessary to grant more flexibility to providers whom were experiencing difficulty implementing 2014 CEHRTs due to the product availability; therefore on May 20, 2014 they released a proposed rule that would make changes to the EHR Incentive Program for 2014 only. The changes would allow providers options to attest for the 2014 reporting period using 2011 CEHRT, 2014 CEHRT, or a combination of both; as well as provide flexibility for users whom were scheduled to attest to meaningful use for Stage 2 to report under Stage 1 (2013 requirements). The proposal did not include any changes to requirements for the 2015 reporting period; providers would still be expected to use 2014 CEHRT for the entire calendar year in 2015.

FINAL RULE RELEASED:

Due to the overwhelming response in support of the proposed changes, CMS released a final rule on August 29, 2014 that will allow providers more flexibility for the 2014 EHR Incentive reporting period.  The rule also extends Stage 2 through 2016 and pushes back Stage 3 till 2017.

Updated Meaningful Use Timeline by First Payment Year

updated meaningful use timline 2014.09.02 from CMS

*3-month quarter EHR reporting period for Medicare and continuous 90-day EHR reporting period (or 3 months at state option) for Medicaid EPs. All providers in their first year in 2014 use any continuous 90-day EHR reporting period.

NEW CEHRT OPTIONS FOR 2014

Providers that are in their first year of participation in the Medicaid EHR Incentive Program who adopt, implement or upgrade CEHRT in 2014 will be required to be on the 2014 CEHRT edition.  All other providers can use the following chart to determine which options are available to them for their 2014 reporting period:

CEHRT SYSTEMS AVAILABLE FOR USE IN 2014

CEHRT systems available for 2014 per CMS 2014.09.02

CMS Resource: 2014 CEHRT Rule Quick Guide – this guide provides corresponding resources based on the option a provider chooses to participate in the EHR Incentive Programs in 2014.

 WHO IS ELIGIBLE TO USE THE CEHRT OPTIONS?

Since reporting options are only available to providers that could not fully implement 2014 Edition CEHRTs due to delays in 2014 Edition CEHRT availability, we thought it would be useful to include some of the public comments concerning this caveat and the official response from CMS:
(Quotes taken from documentation provided by the Federal Register)

Public CommentCMS Response
Precise definition of “not fully implemented” and “2014 availability delays” not sufficiently clear, could encompass endless scenarios, can providers retain the discretion to determine what these terms mean and if not who would ultimately decide?Agreed that some clarification was needed. While some examples were provided it would be impossible to give examples of every possible scenario where inability to fully implement 2014 Edition CEHRT.“Inability to fully implement 2014 CEHRT” intentionally provides the broadest application. Examples of what does not constitute inability are given, and CMS believes that beginning with what is not permissible, rather than what is, represents a far smaller set of circumstances that will both quell providers’ concerns about audits and provide additional parameters on the user of the CEHRT options generally.“2014 availability delays” must be attributable to the issues related to software development, certification, implementation, testing, or release of the product by the HER vendor which affected 2014 CEHRT availability, which then results in the inability for a provider to fully implement 2014 Edition CEHRT. CMS did not intend to allow reasons such as a provider waiting too long to purchase the software, or lack of staff or resources to constitute a “Delay” for purposes of using one of the proposed CEHRT options.
Confusion over whether providers could still attest using 2011 CEHRT options when they have 2014 CEHRT available but could not train personnel or establish new workflow because of late installationThe basis for using one of the CEHRT options stems from a problem with first getting the software installed because of EHR vendor delays, and then fully implementing (including training, workflows, and related activities) 2014 Edition CEHRT in time for a full EHR reporting period in 2014. We note that being able to implement 2014 Edition CEHRT for a part of the reporting period is not considered full implementation of 2014 Edition CHERT. Providers who are only able to implement 2014 Edition CEHRT for part of a reporting period would be permitted to use the CEHRT options in this rule.
After the install of 2014 CEHRT, is there a set standard for what would be considered an adequate amount of time to complete all of the transition process (training, workflow, validation of reporting) Several commenters wanted us to specify cutoff dates for training or workflows where we would find it suitable to allow using the CEHRT options. However, such limits would be impossible for us to adequately capture. Because the number and types of providers involved with the EHR Incentive Program vary greatly, we cannot simply state a hard date or exact time because a large hospital chain would possess different time and workflow requirements, for example, than a single EP. However, we can clarify that in order to use one of the options for the use of CEHRT, the provider must not have had enough time to fully implement 2014 Edition CEHRT, including training of staff, perform system testing, and establishing revised workflows in order to report for a full EHR reporting period. If a large hospital, for example, had their CEHRT installed in August, we expect that this hospital would not have enough time to be able to report for an EHR reporting period in 2014 because the hospital would not be able to train staff or establish the necessary changes in workflow. However, if a hospital had 2014 Edition CEHRT installed in January 2014 and decided to wait until August 2014 to begin training, testing and workflow activities, for example, then this rationale would not be sufficient to establish that the provider could not fully implement 2014 Edition CEHRT due to a delay in 2014 Edition CEHRT availability, because the delay was on the part of the hospital.
Is cost to upgrade and/or financial hardship a valid reason for using 2011 CEHRT options?Providers that do not fully implement 2014 CEHRT due to financial issues, such as the cost associated with implementing, upgrading, installing, testing, or other similar financial issues, would not be able to use the options for CEHRT for the EHR reporting period in 2014. Although we understand that cost is a factor for health providers, as it is with any other business, we proposed the options for CEHRT to address delays in the availability of 2014 Edition CEHRT, and not the costs associated with it. Providers are advised to apply for hardship exceptions under these circumstances.
Could staff turnover or other internal changes be cause for using 2011 CEHRT options?We find staff changes and turnover to be an insufficient rationale for a provider to use the CEHRT options. Some commenters explained that circumstances such as the termination or attrition of staff rendered them unable to train new staff in time to implement 2014 Edition CEHRT. However, we did not intend such rationale to be permissible. Rather, references we made in the proposed rule regarding the inadequate amount of time to train staff stemmed, again, from the fact that EHR vendors were delayed in installing 2014 Edition CEHRT, which, in turn, gave providers little to no time to train their staff on the new software. We consider staff turnover and changes, as well as any other similar situations, to be issues frequently encountered in the normal course of business and therefore insufficient grounds for a provider to use the CEHRT options.
Could problems associated with actual objectives under stage 1 or stage 2 be considered as a suitable reason for using the CEHRT options? (Example if a vendor only released capability for the lab result measure in June and the provider is still waiting for the upgrade to report the measure.)An availability delay is not based solely on whether the software is certified and then installed or not, as many commenters questioned. Rather, providers with 2014 Edition CEHRT installed may nonetheless face a 2014 CEHRT availability delay because they are waiting for vendor software updates, or the software itself is presenting problems with functionality, or when the software does not yet contain all required components. This also may include situations where a problem with the software presents a safety issue, such as when a drug allergy or drug interaction clinical decision support does not function properly, or cases where the vendor identified a functionality problem and sends out patches to fix the problem, requiring the provider to wait until the issue is resolved to use the software. We recognize these issues take time to resolve, and the overall delay in 2014 Edition CEHRT availability may have constrained that time for many providers. So, although we cannot list every possible scenario, installed 2014 Edition CEHRT with delayed or missing software updates, or cases where the software itself renders a provider unable to reliably use the software would be permissible reasons to use the CEHRT options because such issues are considered to be a 2014 Edition CEHRT availability delay. We stress that this does not include, as explained earlier, circumstances where the software functions properly but the provider cannot meet one or more requirements of the measure or the increased thresholds on measures common to both stages. The basis for using one of the CEHRT options stems from a problem with first getting the software installed because of EHR vendor delays, and then fully implementing (including training, workflows, and related activities) 2014 Edition CEHRT in time for a full EHR reporting period in 2014. We note that being able to implement 2014 Edition CEHRT for a part of the reporting period is not considered full implementation of 2014 Edition CHERT. Providers who are only able to implement 2014 Edition CEHRT for part of a reporting period would be permitted to use the CEHRT options in this rule.
Concern over attesting for Stage 2 because of lack of 2014 Edition CEHRT availability among other providers would make it impossible to meet the requirement to send electronic summary of care records for more than 10 percent of transitions of care as many recipients would not yet have the 2014 CEHRT functionality required to receive the electronic document. Request to attest to Stage 1 objectives when these circumstances exist.We acknowledge referring providers may not be able to meet the summary of care measure in 2014, if receiving providers they frequently work with have not upgraded to 2014 Edition CEHRT. We therefore believe a limited exception is warranted for providers who could not meet the threshold for the Stage 2 summary of care measure requiring the transmission of an electronic summary of care document for more than 10 percent of transitions or referrals because the recipients of the transitions or referrals were impacted by issues related to 2014 Edition CEHRT availability delays and therefore could not implement the functionality required to receive the electronic summary of care document. Therefore, we consider the inability to fully implement to extend to those providers for the summary of care document measure at 42 CFR 495.6 (d)(14)(ii)(B) for EPs and (l)(11)(ii)(B) for eligible hospitals and CAHs. A referring provider under this circumstance may attest to the 2014 Stage 1 objectives and measures for the EHR reporting period in 2014. However, the referring provider must retain documentation clearly demonstrating that they were unable to meet the 10 percent threshold for the measure to provide an electronic summary of care document for a transition or referral for the reasons previously stated.
Concern over inability to meet other measures that require specific use of 2014 CEHRT and whether or not these issues such as direct messaging, portal non-use by patients, mapping problems, or other similar measure issues would be considered an inability to fully implement 2014 CEHRT.CMS proposed alternate options only for those providers who could not fully implement 2014 Edition CEHRT for a full EHR reporting period in 2014 because of issues related to 2014 Edition CEHRT availability delays. We did not propose these options in order for providers to be exempted from meeting Stage 2 measure requirements. We do not find that an inability to meet one or more measures, as in the examples cited previously (inability to meet certain thresholds, objection to Stage 2 measures generally, and concerns with measures believed to be outside of provider’s control-such as inability to obtain a beneficiary’s email address), fits within the rationale we proposed for using one of the CEHRT options. Rather, overall concerns and comments requesting changes or exemptions to one or more of the Stage 2 measures and objectives fall outside the scope of this rule, and will not be discussed with any further detail here. Accordingly, for the reasons stated previously, those providers who have fully implemented 2014 Edition CEHRT and cannot meet one or more measures for reasons unrelated to the inability to fully implement 2014 Edition CEHRT due to delays in the product availability cannot use the options for the use of CEHRT and must attest to their stage of meaningful use using 2014 Edition CEHRT as originally intended.
If a provider had no issues with 2014 CEHRT availability could they still be allowed to use the CEHRT options? CMS does not find situations stemming from a provider’s inaction or delay in implementing 2014 Edition CEHRT sufficient to use one of the CEHRT options. These situations include providers waiting too long to engage a vendor or a provider’s inability or refusal to purchase the requisite software update. Such circumstances would not be permissible reasons to use the CEHRT options because they did not stem from a 2014 Edition CEHRT availability delay.We again stress that the proposed rule was intended to allow options for providers that were unable to fully implement 2014 Edition CEHRT for an EHR reporting period in 2014 due to issues relating to 2014 Edition CEHRT availability delays. Therefore, we will not remove the requirement that a provider’s inability to fully implement 2014 Edition CEHRT was based on issues related to 2014 Edition CEHRT availability delays, because this requirement comprises the primary reason for the proposed rule.

 

ARE YOU ON 2014 CEHRT?

Medisoft Clinical and LytecMD users can determine whether they are on a 2014 certified version of the product by opening Medisoft Clinical or LytecMD, going to the Help Menu and selecting “About Medisoft Clinical” or “About LytecMD.” A window will open displaying the Product Version.

  • Version 11 is the 2014 Certified Version. This version has capability of reporting 2014 Stage 1 Objectives and Measures, 2014 Stage 2 Objectives and Measures, and 2014 Clinical Quality Measures (CQMs).
  • Version 9.5.2 is the 2011 certified version.  This version only has the capability of reporting 2013 Stage 1 Objectives and Measures, and 2013 CQMs.

WHAT SHOULD PROVIDERS BE DOING NOW?

  1. SCHEDULE AN UPGRADE IF YOU HAVE NOT DONE SO ALREADY
    The 2014 CEHRT versions of Medisoft Clinical, LytecMD are available NOW! All Medisoft Clinical and LytecMD users that e-prescribe should already be moving towards implementing the 2014 Certified versions of these products prior to October 1, 2014 in order to avoid eRX functionality from being disabled. (Only the current versions of the products accommodate required changes to eRX)
  2. COMPLETE A MEANINGFUL USE ASSESSMENT
    Given that the last available reporting period for 2014 is October 1-December 31 there may still be time to implement 2014 CEHRT and achieve meaningful use under 2014 requirements. Providers should review the requirements for the Stage of meaningful use they are scheduled to attest under this year. Consider all of the add-on products, setup and configuration for both Stage 2 and Stage 1 that must be completed in order to meet 2014 requirements and asses whether or not your practice has sufficient time to implement changes prior to October 1. AZCOMP is available to assist you with a thorough Meaningful Use Assessment that will provide you detailed documentation on required configuration, training and workflow changes that are specific to your practice, along with an estimate of hours that would be involved to make the changes in order to meet meaningful use. This documentation may prove to be invaluable in showing evidence of both engaging the vendor and feasibility of fully implementing 2014 CEHRT.
  3. DETERMINE WHETHER YOU QUALIFY TO USE CEHRT OPTIONS
    If there are reasons that would hinder you from achieving meaningful use for the Stage you are scheduled for on the 2014 CEHRT,  using the guidelines from CMS included above, you should then determine whether or not the reasons would qualify you to attest under one of the CEHRT options.
  4. SELECT THE REPORTING OPTION FOR YOU CICUMSTANCE
    If you determine that you qualify to use CEHRT options, you should then select which option would be most appropriate for your 2014 reporting period.

CEHRT Interactive Decision Tool Flexibility flow chart

To see your options you can use the CEHRT Interactive Decision Tool  provided by CMS that allows providers to answer a few questions about their current stage of meaningful use and Edition of EHR certification, and the tool displays the corresponding 2014 options.

If you are unsure of which Stage of Meaningful use you are scheduled to meet for the 2014 reporting period you can use the EHR Participation Timeline Calculator which will ask you to enter the program you are participating in (Medicare vs Medicaid) and the year you first participated, when the results display simply click on 2014 to see which Stage you are scheduled for this year.

QUESTIONS EACH PROVIDER SHOULD ANSWER:

  1. Which software version will I be using during my reporting period? (2011 CEHRT/2014 CEHRT or both)
  2. Will I be reporting Objectives and Measures for: 2013 Stage 1,2014 Stage 1, or Stage 2
  3. Which reporting period they will I use for my 2014 attestation?
    1. If this is your first year in the program you can attest for any continuous 90 day period, if you are trying to avoid the Medicare penalty for 2015 you must attest by October 1, 2014.
    2. If you have you have attested to meaningful use in prior years you can select any 3 month quarter. (Jan-March, April-June, July-Sept, Oct-Dec)
  4. Do I have supporting documentation for the selections made above? Things to consider:
    1. Providers must report produced by the CEHRT that provide the numbers that are used to attest. Providers are advised to keep copies of the reports as supporting documentation in case of an audit. (Documentation should be retained for six years post-attestation.)
    2. Not all objectives require a numerator and denominator in order to attest. These objectives simply require the provider to answer yes or no to having met the requirements for the measure. CMS has advised providers to keep supporting documentation, including screen shots taken during the reporting period as evidence that the functionality was enabled in case of an audit. (Measures were screen shots are recommended include Drug and Allergy interaction checks enabled, Formularies enabled, implementation of Clinical Decision Support Rules, submit data to immunization registries, or submit syndromic surveillance data)
    3. Providers that plan to attest to have generated lists of patients by specific conditions to use for quality improvement, reduction of disparities, research or outreach (Menu Objective 4 in Stage 1, and Core Objective 11 in Stage 2) should also retain a copy of report dated during the reporting period in case of an audit.
    4. All providers are required to complete a security risk analysis ever year and documentation of the analysis should be retained in case of an audit. The security risk analysis can be completed prior to or during the reporting period but not after. For example, if for their 2014 attestation a provider chooses the second quarter as their reporting period (May-June) the security risk analysis can be completed at any time between January 1- June 30, 2014. Regardless of when the provider actually submits their attestation, if the security risk analysis was not completed before or during the selected reporting period the provider would not qualify as a meaningful user.

ENSURE THAT YOU ARE READY FOR 2015!

Keep in mind that there have been no changes to 2015 requirements. All existing participants, regardless of their Stage still be required to attest for the entire calendar year using 2014 CEHRT, which means providers must plan to fully implement both the software and changes necessary for the Stage they are in prior to January 1, 2015. Make plans now to ensure you are ready for both 2014 and 2015!

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 Medicare/Medicaid programs are constantly changing, and it is the sole responsibility of each provider to remain abreast of  program requirements by consulting the authorities and documentation found directly at http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/index.html