Summary of Care - what you need to know now...

There are a couple of things to note about the Summary of Care measure- Numerator A is no longer required for Meaningful Use or Patient Centered Medical Home according to the recent NCQA update. That being said, there may be other programs you are participating in that are tracking this measure.              

First, there is a new document category in Output Manager called “Summary of Care” .

You should place any referral letters in the Summary of Care Document category so that you will get credit for sending correspondence to the referral provider. While this does not count for MU any longer, it is important for an accurate numerator in other quality metrics.

Second, Numerator B, which measures whether or not an electronic document was sent should be your main focus. The calculation of this measure does not change in version 15, so pay attention to that change and start sending electronic documents now.]

In addition, there is a new requirement for the CQM of Closing the Referral Loop. This requires the following:

1.       Scan the letter from the consulting provider

2.      Index to the Plan / Referral Order

3.      Assign a Document type of “Consultant Letter” or “Consultation Letter”

4.      Review the Referral Order so it is in the Final, Reviewed status (this would be done by the provider if you sent the document for review)

April Special

We are having an April special on classes! If you would like to try out one of our classes for free, send an email to chanelc@ehealthconsults.com and include the title of the class you would like to attend. The New Employee Orientation is not part of this special. Enjoy!

Release Notes

Would you like the cliff notes of implementing Pro EHR version 15? Ones that actually recommend how to use the new functionality? Get them by either attending the Implementing 15.0 class or send a request to chanelc@ehealthconsults.com. If you are not attending a class, the cost is $35.00.

**Screen shots are from Allscripts Professional EHR

eHealth Consulting News and Updates: MU and PHO

Meaningful Use and Public Health Options Q&A Forum
 

Join Trisha Conway on Wednesday, February 24th at 10:30 AM EST for a Q&A session regarding Meaningful Use and Public Health Options. 

Let’s discuss how to handle the Public Health Options for Meaningful Use:

• Do you really need to connect to a registry that provides no clinical value?
• What documentation should you keep to demonstrate an exclusion?
• What is the real intent?

Take care,

Trisha Conway |Principal Consultant

919.696.0371 | C

trishaconway@ehealthconsults.com | www.ehealthconsults.com

Copyright © 2016 eHealth Consulting, All rights reserved.

eHealth Consulting News and Updates: PHO

Greetings! Can you believe it is already the second week in February? I can’t. What significance does that hold? It means that you have 21 more days to become “Actively Engaged” with a public health registry. It also means that PQRS submissions will be due soon as well. Different registry vendors have different cut off dates, so make sure you are familiar with yours.

There is a lot of buzz lately about public health options, so I wanted to take a few minutes to review some key points. First and foremost, the intent of the measure is to exchange meaningful data with another entity that can use the data to generate meaningful results. It isn’t intended to be an exercise in futility. In addition, a “public health registry is one that is administered by, or on behalf of a local, state, territorial, or national PHA and which collects data for public health purposes.”

There are three measures:
Measure 1 - Immunization Registry Reporting: active engagement with a PHA to submit immunization data.
Measure 2 – Syndromic Surveillance Reporting: active engagement with a PHA to submit syndromic surveillance data.
Measure 3 – Specialized Registry Reporting: active engagement to submit data to a specialized registry.
EP Spec Sheet at CMS.gov 

So how can you meet these measures?
The first two are pretty straightforward, the public health agency in your state either has an Immunization Registry or Syndromic Surveillance registry or it does not and you can typically find a statement to that effect on your state Department of Public Health website. Documentation of your registration to participate, participation, or documentation that the PHA does not currently have an Immunization or Syndromic Surveillance registry available are important for audit purposes. 

If you registered last year or in a previous year and there has been no change in the availability, you do not have to register again. As noted in the specification sheet, registration allows the EP to meet the measure despite the PHA’s limited resources to move forward. Registration must occur within the first 60 days of the reporting period (no later than 2/29/2016). If there is no registry at the beginning of the reporting period, you qualify for an exclusion. Other exclusions can be found on the EP Spec Sheet link above.

If you are excluded from either Immunization Registry or Syndromic Surveillance or both, you must look to the Specialized Registry options. You can use two specialized registries to meet the Public Health Options measure. You can also use “methods beyond the functions of the CEHRT to meet the requirements”. This means you can think outside the box and you do not necessarily have to purchase something extra to meet the measure. The word “jurisdiction” is also a key part of the Specialized Registry measure.

“An EP must complete two actions in order to determine available registries or claim an exclusion:
•    Determine if the jurisdiction (state, territory, etc.) endorses or sponsors a registry; and,
•    Determine if a National Specialty Society or other specialty society with which the provider is affiliated endorses or sponsors a registry.”

Recommendations:
1.    Contact your public health agency (ideally by email so you have documentation) to ask about specialized registries that are pertinent to your specialty.
2.    Contact your specialty local, state, and/or national organization (ideally by email so you have documentation) to ask if there are opportunities for data sharing. 
3.    Contact the HIE in your state, if available, and find out the data sharing capabilities and if appropriate, register your intent to participate.
4.    Attend the Reporting Module class to discover what you can already do with your data.

Obtaining your Certification ID

The CHPL website has changed! Follow these steps to find the EHR Certification ID:

1.        Go to http://oncchpl.force.com/ehrcert
 

2.       Enter Allscripts Professional EHR and click Search, select the checkbox beside the product you used.
Note the YOUR PRODUCTS section at the top of the screen with the down arrow has changed to (1). Click the down arrow to expand, displaying more detail about the product or products you have selected.

3.       Click on View Progress

4.      On the View Progress screen, you will see the information about the product and in the bottom right hand corner the blue “Get Certification ID”

5.      The CMS EHR Certification ID displays. Choose either Email or Print or perhaps both.

Comments on the Modifications to Meaningful Use in 2015 Through 2017

Reporting Period, Page 14:

Due to the many obstacles in meeting the Stage 2 objectives to date for patient engagement and direct messaging, as well as vendor challenges with delivering use-able, stable, compliant software, the shortened 90 day reporting period will allow providers an opportunity to successfully attest during the 2015 calendar year. The flexibility of the reporting period beginning outside of a specific calendar quarter is important for successful attestation in 2015 considering when this rule will be finalized.

Patient Engagement, Page 15:

I agree that the ability to test whether or not the physician has the functionality needed to interact with their patient (Secure Messaging and Timely Access) is a much better means of measuring patient engagement. Physicians have no control over the patient’s level of comfort towards allowing their health information to be published online or the adoption of messaging related to health matters. Adoption is increasing, but these two measures are definitely time intensive, can detract from the patient visit and often times require hiring additional personnel to make sure the provider does actually meet the measure threshold.

Patient Electronic Access, alternate proposal for threshold calculation, Page 50:

The measure for VDT (b) should be based on a denominator of patients with an office visit during the reporting period with a web account. Basing the threshold on patients that currently have an account would give the provider the appropriate denominator to calculate a meaningful threshold. Making this change would also normalize the data for comparison across providers. For example, you could compare a rural provider with an urban provider because the basis of the measurement is now equivalent.

Summary of Care, Page 67:

Exchanging C-CDA documents electronically has been a tremendous challenge for providers. While the providers that have the required CEHRT are able to create a compliant C-CDA and are able to send the document through direct messaging, other vendor systems are not necessarily able to receive that data in a readable format. It wasn’t until just recently that confirmation of receipt was available from the receiving entity because it required the receiving system to communicate through the HISP and then back into the receiving system. In light of these challenges, I request that you specifically define electronically. Does that include fax? Traditional email with encrypted attachments? Are there any other means you consider electronic?

In addition, will the exclusion posted in the Modifications to the Medicare and Medicaid Electronic Health Record (EHR) Incentive Program for 2014 and Other Changes to the EHR Incentive Program be upheld such that if the referral sources the provider is accustomed to using do not have direct messaging then the provider can claim an exclusion to this measure?

Public Health Options – Immunization Registry, Page 198:

The Immunization option under Public Health reporting reads as if only a bi-directional interface would count as successfully meeting this option – “receive immunization forecasts and histories”. Please clarify whether or not this is the case and if there will be any grandfathering of current registries. Most states are not able to exchange immunization data in a bi-directional manner and if required, this would pose a significant obstacle and financial hardship for providers to meet the public health option for immunization registry. To date, immunization registry reporting has been the most successful interoperability measure of meaningful use.

Public Health Options – Case Reporting, Page 198:

Cancer Registry reporting is one method of case reporting that many states support, but few CEHRT vendors are able to support. If a practice has purchased certified EHR technology that is unable to transmit to their state cancer registry, would they still be able to meet the definition of active engagement if they register their intent to participate with the state registry as soon as their EHR technology is able to transmit?

Providers need additional examples of case reporting and how they can actively engage in the event that they are excluded from all other public health options. Would a manual batch C-CDA export followed by a manual batch import or upload to a health organization meet the requirements for case reporting?

Public Health Options – Clinical Data Registry, Page 198

Can you further define clinical data registry? For example, if a CEHRT supports an extract, transform, and load process to move data from the client database to a cloud based data warehouse so that the data can be normalized, analyzed and reported on in various methods (PQRS, CQMs, PCMH, etc.), would that meet the definition of clinical data registry reporting?

Meaningful Use and PQRS Extension

We still have time, it is not too late!

The Centers for Medicare and Medicaid Services has extended the attestation deadline for Eligible Professionals participating in the Medicare Meaningful Use program to March 20, 2015, this is great news!

Use the following worksheets to assist with your attestation:

Stage 1 2013 Attestation worksheet

Stage 2 Attestation worksheet

The PQRS deadline was also extended to March 20, 2015. Be sure to verify submission deadlines with your vendor for PQRS also.

This extension means you still have time to both make money this year and avoid penalties in future years.  Remember that 2014 is the last year to receive an incentive for PQRS and the last year to begin participating in the Medicare MU program and be eligible for any incentive money.  Do not leave your incentive money behind, Meaningful use is possible and we can help you!

MEDICAID MU ATTESTATION DEADLINE IS STILL TODAY -- 2/28/2015.

PQRS – Don’t leave your money on the table!

Did you know you could still participate in PQRS for 2014 and not only receive your 0.5% reimbursement based on charges for covered services billed in 2014, but also avoid the 2.0% penalty next year? The deadline for reporting is now as late as March 13th with some vendors.

What is PQRS?

A separate incentive program from meaningful use that is available to eligible providers who provide Medicare part B services. Submitting clinical quality measure data associated with meaningful use does not automatically meet the PQRS reporting requirement, even though some of the measures do overlap.

Who qualifies?

Physicians, practitioners and therapists that bill Medicare Part B services. For a full list, go to: http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/Downloads/PQRS_List-of-EligibleProfessionals_022813.pdf .

What do you do?

1. Choose a reporting option: Clinical registry reporting or claims registry reporting. You can access a list of vendors and pricing on the Medicare website: http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/Downloads/2014QualifiedRegistries.pdf .
2. Based on your choice in #1, you may be able to report on a measure group (Asthma, HTN, Low back pain, etc.) versus picking individual measures. This is easier because it involves a 20 patient sample, 11 of which must be Medicare.

• Measure group – Pick the patient sample based on the measure group you choose, for example, the Preventive Care group is based on a patient sample of 50 years and older with a new or established visit (99201-99205, 99212-99215), so you would pick 20 patient that meet that criteria, 11 of which must be Medicare patients. Then audit those charts against the measures included in that particular measure group.
• Individual measures – Pick 9 PQRS measures based on the measures supported by the vendor you choose and follow the vendor’s instructions for collecting and submitting the data.

Need help? Let us know on the Contact page.

Meaningful Use in 2014 - The Flexibility Rule can make a difference for you!

Do you find that you are forced to use the last calendar quarter of 2014 as your meaningful use reporting period due to installation delays? Are you finding that the certified EHR technology you need to support you in meeting the Stage 2 objectives is just not available or has not been implemented yet? Are you experiencing training nightmares as a result of these delays? If you answered yes to one or more of the questions above, you may experience significant relief from the Flexibility Rule published by CMS on 9/4/2014. Here are some key points:

1.       Providers may use any calendar quarter in 2014 to capture data for attestation, they are not limited to the last quarter of the year.

2.      There is a special provision for providers that are unable to meet the Summary of Care, measure 2, due to the inability to identify recipients of an electronic transmission. In other words, if none of your referral providers have direct addresses for you to send your referral documentation (Summary of Care consolidated-CDA), this would apply to you.

3.       Providers may be able to attest to the 2014 Stage 1 objectives and measures and in some special circumstances the 2013 Stage 1 measures thanks to the flexibility rule.

4.       Providers will have to prove that they were not able to fully implement the 2014 edition of CEHRT. This could be due to availability and timing of software installation (clinical decision support, direct messaging, and clinical quality measure availability, for example) and ties into the ability to implement any new workflows and/or processes necessary to meet the objectives. This is a bit of subjective area so documentation is key in justifying your choice.

Once you make the decision as to whether or not you are eligible for a flexibility option in 2014, the CMS (Table 2) below, does a good job of giving you available options.

Do you know what is in your database?

Data exchange is a hot topic lately. The idea of a health care system with complete and accurate data exchange is very powerful and can open the doors to better, more cost efficient care. With Stage 2 of Meaningful Use forging the way, everyone is in a hurry to get connected without necessarily thinking through what the data looks like and the safeguards that should be implemented to protect your data. As health care providers, we must be vigilant about maintaining the accuracy of the data that we share with others.

Why isn't my data accurate you may wonder?

Data Issue # 1: One reason for inaccurate data is attributable to renaming of clinical items. Imagine that you are searching your EHR for a diagnosis you don't use very often, Kidney Disease for example, and you cannot find it after 4 or 5 tries. Because you have 40 more patients to see, you enter Keloids and change the name to Kidney Disease. Fortunately and unfortunately, the data in the database is identified by one or more codes and just because you change the name or description of the clinical item, the code does not change.

Implications: If I send the chart of the above person using some form of data exchange, the recipient will believe the patient has a history of Keloids instead of Kidney Disease. This has significant clinical implications and is unfortunately very common.

Data Issue # 2: A second reason data is inaccurate is due to the use of free text diagnoses, allergies, medications, etc. Since text varies and cannot be accurately coded it does not exchange well.

Implications: In the event of free text clinical data, you are looking at data being being omitted altogether from the exchange or exchanged in a format that is not usable by the receiving system. This can be quite serious if a patient has a true allergy to a medication that is not communicated.

These are just a couple of the significant issues I am aware of in looking at real life data. It is imperative that we work together towards cleaning up the data we are sharing. 

Consider joining me on the 27th to talk more about exporting and importing patient data.

Have you visited Caregiver Options lately?

I often find that one of the WOW factors when training on the EHR is showing users where they can set Caregiver Options. Setting up your favorite or most frequently used screen settings can save you countless seconds, minutes, perhaps even an hour throughout your day. 

Each release typically comes with some additional gems hidden away, particularly in the area of Quick Lists. Some of the more popular options include:

• Result Views - you can set a default view when you enter the results screen from either the desktop or with a patient in context. Perhaps when you are in Desktop mode and you enter the result screen, you only want to see Ordered, Past Week by or on your behalf. When you enter in Patient mode, you want to see All Statuses, Labs, Past Year. You can designate that in caregiver options on the Result View screen.
• History - Do you get tired of deleting Other Past History when you include active on the History screen? Are you continuously clicking on the History/Medications tab to include current medications? A quick click of a couple of check boxes in Caregiver Options/History can change that forever. Check Exclude Other Past History and Include Current Medications.
• Lab Orders - Are your caregivers complaining that there orders are showing up under the MA or Nurse instead of them? This routing is controlled in Assessment & Plan. In Caregiver Options, you can preset the ordering on behalf of caregiver for orders placed in A&P to the Appointment Caregiver. This way when the MA or nurse order a test or medication, the Ordering on behalf and Notify fields automatically get set to the provider which the patient was scheduled to see.
• Quick Lists - Tired of Scrolling through lists? Most lists can accommodate a Quick List which pulls items that you choose to the very top of the list above a dashed line. Popular ones include Medication Units, Frequency and Refill quantities, Billing Levels, Caregivers and Subjects, but there is quite an extensive list.

Check it out!

CMS finalizes flexibility for providers in 2014

Are you struggling with figuring out how you are going to meet some of the more challenging measures in Stage 2? Are you finding that the technology you need to support you in meeting the objectives is just not available or has not been implemented yet? Do you find that you are having to wait until the last calendar quarter of 2014 in order to achieve implementation of the necessary functionality to attest to the 2014 Stage 2 measures?

If you answered yes to one or more of the questions above, you may experience significant relief from this final rule. There were a couple of key points I noted as I read through the final rule which is due to be published on 9/4/2014.

1. Providers may use any calendar quarter in 2014 to capture data for attestation, they are not limited to the last quarter of the year. (page 36)
2. Providers will have to prove that they were not able to fully implement the 2014 edition of CEHRT. This could be due to availability and timing of software installation (clinical decision support, direct messaging, clinical quality measure data) and ties into the ability to implement any new processes in order to meet the objectives. This is a bit of subjective area so documentation will need to be available to justify. I am happy to go into more detailed discussions in the Q/A session on Sept 5th (see the Education page). There are simply too many scenarios to discuss here.
3. There is a special provision for providers that are unable to meet the Summary of Care, measure 2, due to the inability to identify recipients of an electronic transmission. That too requires distinct documentation.

Once you make the decision as to whether or not you are eligible for a flexibility option in 2014, the CMS table (Table 2) in the above link, does a good job of giving you available options. The CQM options get a little tricky if you are using the 2011/2014 combination since you are allowed to use an alternate reporting period for the CQMs.

The monster behind measure number 9 - The Security Risk Assessment/Update

Meaningful use objective number 9 continues to stump many practices as far as what is required. So much so, that CMS has dedicated many resources to this one measure. Let’s review the measure and discuss what is really needed before you attest to meeting measure # 9.

The CMS Eligible Provider Specification Sheet, defines the measure as:

Conduct or review a security risk analysis in accordance with the requirements under 45 CFR 164.308(a) (1), including addressing the encryption/security of data stored in CEHRT in accordance with requirements under 45 CFR 164.312 (a)(2)(iv) and 45 CFR 164.306(d)(3), and implement security updates as necessary and correct identified security deficiencies as part of the provider's risk management process for EPs.

If you are using Professional EHR 13 or later, you can be assured that all the 2014 certification criteria related to security were met. In fact, you can print out the proof by accessing the ONC website, searching for the Professional EHR product, click the name of the product you are using and you will get a full report of all the criteria passed for 2014 certification, including security. Unfortunately, it doesn't stop there! You must also evaluate your office environment, staff policies and procedures, etc. to fully complete the security assessment. Some examples of needed documentation include:

• How do you control access to your office space during and after office hours? If an employee leaves or is terminated, how do you insure that the access is also terminated?
•  How is PHI handled at your workstations? Do you have privacy screens? What are the Lock Out settings in the EHR? How do you address function access to PHI?
• How often do you train staff on HIPAA requirements? When was the last training? What was covered? Do you have sufficient policies and procedures to address both HIPAA and the meaningful use requirements?
• How often do you review and edit policies and procedures? How is this handled in your office (executive board meeting, designated committee, etc)?
• Do you have a security action plan?  How often are backups done? How are they stored? If the backup is on an external device, is the data encrypted? Do you store files with PHI on your laptop (spreadsheets, analytical files, CCDs or patient chart exports? Are those files encrypted?
• Are the planned actions, owners and dates documented in that security action plan? How often do you update it? You must review and update during your meaningful use reporting period at a minimum to meet the measure.
  
  The bullets above are just examples of topics to evaluate and include in your security assessment.

Though it may seem quite ominous, you have likely addressed much of it within your HIPAA compliance plan and regular policies and procedures.

In addition and the best news is that there is a free tool available, provided by the government to assist you in completing your security assessment. You can also contract with an external vendor to assist you in completing the security assessment. Please remember that regardless of which method you choose, you are still ultimately accountable. 

Have additional questions? Join the question and answer session on Sept. 5th posted on the Education page.

Secure Messaging - Understanding Patient Engagement

It is important to understand the requirements and exclusions of the Secure Messaging measure. The objective of course is to encourage electronic communications between a patient (equates to patient or the patient’s representative) and a provider regarding the patient’s health information. That communication can be initiated by either the patient or the provider with a response from the patient. The key being the patient has to engage.

Before I discuss ways to meet the measure, let’s review the exclusion. On the CMS website, eligible provider specification document it states, “Any EP who has no office visits during the EHR reporting period, or any EP who conducts 50 percent or more of his or her patient encounters in a county that does not have 50 percent or more of its housing units with 3Mbps broadband availability according to the latest information available from the FCC on the first day of the EHR reporting period.”

You can determine broadband availability here. Then click on “Rank your geography”, “Rank within a State”, “County”, Select you State and click on “Generate the List”. The counties in your State will be listed in order of % with access speeds of >3Mbps. There was one in North Carolina that fell below 50%. I found this interesting : ) and certainly not the easiest data to find!

Ok, now that we have that out of the way, let’s talk about the messaging part. Messages must use the certified EHR technology (CEHRT). Typically this is a portal solution. It may be the portal your complete CEHRT used for certification or it could be a different portal that is certified as a modular component. Depending on the solution, percentages can be obtained as follows:

• Complete CEHRT solution: the provider’s % will be generated out of the reporting solution for the 2014 complete CEHRT.
• Modular product: generate the messaging report out of the modular component and then compare that list to the denominator generated from the complete CEHRT to get the accurate % for attestation. Don’t forget the put this solution in the cart when you generate your Certification ID on the ONC website.

The actual message exchange between the provider and patient should be about relevant health information, for example, refill requests, request for instructions about a particular condition or treatment, etc. and not the local golf tournament. Either the patient can generate the message to the provider OR the provider could generate the message and the patient could respond. Once this occurs, any provider in the practice who has seen the patient during the EHR reporting period should receive credit in the numerator. This is referred to as a halo effect.

Other ways to achieve this measure would include:

• Educating the patient on how to send a message to a provider while they are in the office.
•  Asking for a patient to respond to a clinical reminder message sent to the portal.
• Asking patients to verify they have reviewed their lab results and do not have additional questions or to include questions in their response.

Whether or not the provider responds to the message is not part of the calculation since it may be more appropriate to respond by another means.

AUDIT – Part 2: Prepare going into Stage 2!

1)    Just prior to attesting, generate a summary report for each Core and Menu measure with a calculated threshold. This will be used to validate the numbers you enter in the attestation portal. Reports should clearly state the Pro EHR version of the CEHRT (certified electronic health record technology) used to generate the report.

a)    Core measures:

i)     CPOE w/ Drug Interaction Checking*, ePrescribe w/ Drug Formulary*, Demographics, Vital Signs, Smoking, View Download, and Transmit (Timely Access and Online Access), Clinical Summaries, Clinical Lab Tests, Patient Reminders, Patient Education, Medication Reconciliation, Summary of Care, Secure electronic messaging, Immunization Registry, Clinical Decision Support

(1)  Summary of Care measure 3 – evidence that a provider that uses a different EHR received a direct message Referral Summary of Care C-CDA document from the practice.
(2)  Patient Lists (the actual de-identified list of patients including the clinical criteria used)
(3)  Protect electronic health information (Security Risk Assessment): Documentation demonstrating your Security Risk Assessment review for that reporting year and any educational or process changes which occurred during the reporting year to make sure you are maintaining the security of your data. This assessment is outside of the EHR an ideally includes an action plan with responsible parties. It needs to be reviewed and updated regularly within your reporting period. A tip sheet can be located here on the CMS website.

ii)    Qualifying for an exclusion for a core measure is the same as successfully meeting the measure; however, you should still be able to prove why you qualify for the exclusion.

b)    Menu Measures – the three you have chosen from the following:

i)     Electronic Notes, Imaging, Family Health History, Syndromic Surveillance+, Cancer Registry - or Specialized Registry  - .

ii)  -  Not supported by Allscripts Professional EHR as of this posting date. Supplemental certified software would be needed to choose these as menu measures.

+ Most states do not accept syndromic surveillance data from ambulatory providers. 

2)    Optional reports in support of the Yes/No attestation measures

i)     The Non-calculated measure report provides support for the Yes/No attestation answers. Services that are enabled, such as: CDS Recommendations, Drug Interaction Checking, Drug Formulary, Immunization Registry and Syndromic Surveillance* are indicated on this report. You can use this report for validating these measures where on for the duration of the reporting period or screen shots from the product demonstrating the use of these services.

ii)    The CDS recommendations report will validate the provider has chosen at least five recommendations and the associated clinical quality measure number. This report should also validate that these measures correlate with a minimum of four of the nine Clinical Quality Measures chosen.

3)    Clinical Quality Measures – 9 clinical quality measure attestation reports and evidence of submission per CMS direction should be included with this documentation.

4)    Keep this documentation for at least SIX YEARS in at least two formats (saved on your computer, flash drive, external hard drive, printed copy – these are examples of different formats referenced here.

If you think Stage 2 is impossible, please call, it certainly is possible and you shouldn't leave your money on the table!

An AUDIT – What do you mean? What do I do?

First, don’t panic! When a provider attests for Meaningful Use there is always the possibility of an audit. This can be a very stressful experience if you do not have the documentation you need to justify your attestation. Avoid all the anxiety by making sure you have the appropriate supporting documentation and you keep that documentation for at least 6 years. 

Stage 1 Meaningful Use:

Keep the following documentation in either a .pdf format saved in more than one location or perhaps a combination of .pdf files and printed copy.

A summary report from the Reporting Module for the attestation reporting period for each Core and Menu measure with a calculated threshold. (Documentation should clearly identify the Pro EHR version of the CEHRT (certified electronic health record technology) used to generate the report.)

Core measures:

1. CPOE, Drug Interaction Checking**, Problem List, ePrescribe, Medication List, Medication Allergy List, Demographics, Vital Signs, Smoking, Clinical Decision Support**, Clinical Quality Measures, Electronic Copy, Clinical Summary
2. Protect electronic health information (Security Risk Assessment): Documentation demonstrating your Security Risk Assessment review for that reporting year and any educational or process changes which occurred during the reporting year to make sure you are maintaining the security of your data. This assessment is outside of the EHR an ideally includes an action plan with responsible parties. It needs to be reviewed and updated regularly within your reporting period.

Menu Measures (the 5 you chose) from the following:

1. Lab Tests, Patient Reminders, View Download, and Transmit (Timely Access), Patient Education, Medication Reconciliation, Summary of Care, 
2. Drug Formulary**, Patient Lists**, Syndromic Surveillance**, Immunization Registry**
3.  **Optional reports in support of the Yes/No attestation measures

•  The Non-calculated measure report provides support for services that are enabled, such as: CDS Recommendations, Drug Interaction Checking, Drug Formulary, Immunization Registry and Syndromic Surveillance*. You could either use this type of proof or you can take screen shots from the product demonstrating the use of these services. (Snipping Tool is a great screen shot tool that comes with Windows)
• The CDS recommendations report will more specifically validate the provider has chosen at least 1 Clinical Decision Support recommendation.

Exclusions

Qualifying for an exclusion for a measure is the same as successfully meeting the measure; however, you should still be able to prove why you meet the exclusion.

 If you don’t have your documentation, please do call for help or fill out the form on the Contact page!

Clinical Decision Support - interesting info from CMS

Spotlight On: Clinical Decision Support

07/21/2014

News Updates | July 21, 2014

Learn More about Clinical Decision Support Interventions

Clinical Decision Support (CDS) is a key functionality of health IT that contributes to improved quality of care and enhanced outcomes by avoiding errors and adverse events, improving efficiencies, reducing costs, and enhancing provider and patient satisfaction.

In Stage 1 of meaningful use, eligible professionals and eligible hospitals must implement one CDS rule. In Stage 2, eligible professionals and eligible hospitals must implement five CDS interventions and enable and implement functionality for drug-drug and drug-allergy interaction.

New CMS Guidance for Clinical Decision Support Interventions
Although the trigger intervention certification criteria require EHR technology to produce an alert at relevant points during patient care, the meaningful use objectives give providers flexibility in the types of CDS interventions they employ, and do not limit them to “pop-up” alert interventions.

Providers can meet the objectives by using other kinds of CDS, including, but not limited to:

• Clinical guidelines
• Condition-specific order sets
• Focused patient data reports and summaries
• Documentation templates
• Diagnostic support
• Contextually relevant reference information

For more information on CDS, review the Clinical Decision Support tipsheet and the new FAQ.

You should definitely have a primary and a secondary plan for CDS. Why? Sometimes the automated CDS recommendations are disabled by either support as part of researching a ticket you submitted or at your request due to performance issues.  Having a back up method gives you peace of mind that CDS recommendations are always on :)