By Jim Tate, EMR Advocate
Meaningful Use Audit and CEHRT Expert
Twitter: @JimTate, eMail: Inquiry@meaningfuluseaudits.com
Wave three is hitting the Meaningful Use (MU) shore. A foundational requirement in the CMS EHR Incentive program has been the use of Certified Electronic Health Records Technology (CEHRT). The definition of CEHRT has evolved from the initial wave (2011 Edition) through wave 2 (2014 Edition) to the cresting wave 3 (2015 Edition). For vendors who must certify their CEHRT under the new guidelines careful attention must be paid to timelines, required functionality, and deepening documentation requirements.
First things first: The MU use program has been voluntary on the part of eligible hospitals (EHs) and professionals (EPs). However, non-participation meant the loss of Medicare EHR incentives followed by reductions in Medicare reimbursements. Under the coming MACRA Part B reimbursement scheme it is obvious that providers who elect to skip being a “meaningful user of CEHRT” will pay a higher and higher price. Vendors also know that if they do not maintain active certification they will pay a dear price in the market place.
What follows is an extremely high level view of what I consider to be several of the most significant things to know about wave three of CEHRT.
[tweetthis]. @JimTate reviews basics of stage 3 #EHR technology; EPs, EHs required to use 2015 #CEHRT by 1/1/18[/tweetthis]
When do providers have to begin using 2015 Edition CEHRT? – All EPs and EHs will be required to be at Stage 3 and using 2015 Edition CEHRT no later than January 1, 2018. Providers who choose to meet Stage 3 with the 2015 Edition in 2017 will have the benefit of only having a 90 day reporting period. Everyone else will need to hit the mark for the full year.
What are some of the areas the 2015 Edition will require in terms of significant development, planning, and heavy lifting?
- Beyond the portal: EHRs will need to have open interfaces (via API functionality) to allow other applications to gain access to patient data.
- More documentation: Vendors will need to provide a more robust and documented “user centered design” process. In addition, the Quality Management System requirements have been elevated.
- C-CDA: a new version will be required with a more detailed testing process.
- CQMs: QRDA files must now be imported and not input as part of a manual process.
- Secure Transport: The Direct protocol was a big step up in the 2014 Edition but 2015 Edition will now also require the Direct Edge protocol. Testing will not be for the faint of heart.
The ONC Testing Bodies have been preparing guidance, clarification, and testing scripts for the new 2015 Edition of certification. It is interest that since the 2014 Edition will stay remain valid until the end of 2017 testing will also continue for that Edition. So we will continue for some time to see both 2014 and 2015 Edition testing and subsequent certifications being announced.
Final thoughts: a word to the wise. The testing of 2015 Edition of CEHRT will try the patience of vendors. Some of the testing tools employed are incredibly complex and require many steps. A deep understanding of the requirements is critical to ensure that significant money and development time is not wasted because of potential vendor knowledge gaps.
Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. His unique combination of skills has brought successful outcomes to hospitals at risk of having their CMS EHR incentives recouped. He led the first appeal challenge in the nation for a client hospital that had received a negative audit determination. That appeal was decided in favor of the hospital. He has also been successful in leading the effort to reverse a failed appeal, even after the hospital had received notification of the failure with the statement, “This decision is final and not subject to further appeal”. That “final” decision was reversed in less than a week. If you are a hospital with questions or concerns about the meaningful use audit process, contact him at: audits@emradvocate.com.