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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.

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