Category: Electronic Medical Records

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Cloud-Based versus Server Based EHR Comparison

Since the onset of the COVID-19 pandemic, small, independent health care practices have changed workflows to accommodate telemedicine visits with patients. Some physicians, providers, and staff may also work from home occasionally. Although a hectic time, telemedicine has helped practices cope with quarantines and social distancing requirements, while also adapting to changing patient needs. With a provider’s ability to treat patients remotely comes a necessary workflow requirement of continuing the ability to access patient health records quickly and securely. Implementing an appropriate electronic health records system for your practice delivers to your providers and staff the tools to work safely outside the confines of your practice’s walls.

Health care practices can choose from multiple technologies to access EHR remotely, although a server-based system requires an additional remote access infrastructure. The difference between a cloud-based electronic health records (EHR) system and a server-based EHR system is mostly in where the programming and data reside. Both methods are similar in that functionality and essential features attempt to accomplish the same processes. Both systems collect patient information, maintain accurate health records, organize and compile data into informative and sharable formats, and facilitate effective communication with medical providers, payers, and patients. The health care practice controls and manages all aspects of a server-based system. EHR system developers manage cloud EHRs programming and data. The cloud system eliminates the practice’s need to maintain internal servers, monitor backup procedures, or to develop redundancy and resiliency protocols that ensure continuity of service and reliable access to stored data. 


UPFRONT COSTS

Cloud systems have the advantage here. EHR is much more complicated than simple practice management or billing system. For a server-based system to work correctly and speedily requires a practice purchasing one or more servers. Keep in mind, the premise of our discussion includes your ability to work from a remote location. Don’t ask a single computer to act as an application server, data server, and remote access server, and also work well. A cloud-based system eliminates the server(s) requirement.


MONTHLY COSTS

Both types of EHR systems have ongoing monthly or annual costs for services, support, and software updates. For a cloud-based system, you’re still paying for server infrastructure hosted by the software developer, just monthly instead of upfront. You may see a more substantial monthly cost with cloud systems than server systems, especially for practices with more physicians, providers, and users.


TOTAL COST OF OWNERSHIP (TCO)

TCO is tricky. For larger practices, especially, you may experience a lower TCO over three to five years with a server-based system. But that assumes the need for only basic maintenance requirements and no major server failures during the period. Any major networking and server issues can quickly eat into the savings. Plus, what many models don’t figure in is the need to replace your server(s) after four or five years, adding a new expense. The edge for the total cost of ownership costs usually goes to server-based systems, but only barely, and not without risks.


CASH FLOW IMPLICATIONS

You may have heard the expression “cash flow is king.” Despite a possible advantage in TCO, a server-based system still requires a tremendous up-front cash outlay. Cloud systems provide the benefit of predicting and knowing your monthly cash flow needs in advance.


DATA AND SYSTEM CONTROL

A server-based system provides you complete control over your systems and data. With that control is the requirement to secure your data and protect your systems adequately. If the Internet is down, a server-based system still works in the location where the server resides. If you have people working remotely from the server, they are unable to work on the network. With a cloud-system, anyone without Internet is down, but not all locations are necessarily offline. Plus, you have backup options available in instances where Internet access is temporarily lost. 


RCM COMPANIES

Revenue cycle management companies that perform billing, coding, collection, and other services on behalf of health care practices can leverage a cloud-based EHR to accommodate a provider’s clinical record keeping needs and the RCMs billing needs. All users can access integrated clinical and billing data from various remote locations with a cloud-based EHR. Cloud-based systems give RCM companies an opportunity to continue supporting practices when the transition toward electronic health records.


The crisis facing independent health care practices is leading more practices to adopt EHR. No one solution meets the needs of every healthcare-related company. Sunrise Services can help you with figuring out the best options for your office, and the associated costs to meet your needs and goals. Reach out to Sunrise with your questions, concerns, and goals. We’ll help create a plan suitable for your practice.

Navigating eRx in Medisoft Clinical
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Navigating eRx in Medisoft Clinical v11.2.1

Sunrise Services recently concluded Medisoft Clinical upgrades to version 11.2.1. The latest version incorporates a new ePrescribing module based on an enterprise service. One tremendous advantage of the enterprise version is the elimination of downloading, installing, and managing insurance formularies and drug interactions. Instead, Medisoft Clinical incorporates these features into the service!

NOTE:  This article is for Version 11.2.1 only. If you have not updated to version 11.2.1, please contact us so we can guide you on any requirements to upgrade

As the lead Medisoft Clinical support technician for Sunrise Services, I’ve experienced with you, first-hand, how any change in a feature can affect your workflow. Therefore, I’ve compiled some of the most common questions, issues, and confusions clients experience with the new eRx service:

When you look under the ‘RX/Medication’ tab in a patient chart, you may notice several different status codes.  You must look at the entire picture to get an understanding of what the status is for the selected prescription.

Pending – The prescription has not yet left the system. No action required unless the status changes to ‘Error’,

Queued – The order is in the system and queued up to send to Surescripts and the pharmacy.  If the RX remains queued for more than 10 minutes, contact support to investigate.

Verified – The pharmacy received the prescription and confirmed receipt with a message sent through Surescripts.

Error – The prescription did not make it to the pharmacy, resulting in an error message received from Surescripts or the pharmacy. If the error message appears to be one you can remedy, correct it yourself. Otherwise, or if in doubt, call Sunrise for support.

Completed – The Rx was put in the system for a different provider and is complete. Completed prescriptions occur when you perform a ‘Medicine Reconciliation.’ Remember to remove the medicine when it is no longer active.  Just highlight the medication and move to ‘Historical.’

Sent – You’ve received no additional information from Surescripts or the pharmacy after sending the prescription.


Let’s take a closer look at the ‘Sent’ status:

If you created a paper Rx, then it is ok to have a ‘Sent’ status. On a printed prescription, the system has no way to validate whether the pharmacy received the order, so the system marks it as “sent” to indicate completeness. 

If you made an Electronic Prescription, or eRx, and the status is stuck on ‘Sent,’ then you must investigate further. The ‘Sent’ status indicates the prescription did not make it to the pharmacy, or the pharmacy sent back a denial.  You’ll see this status typically when a refill request is filled and is older than 14 days.  When you have a refill request present on the eRx Worklist, it’s in your best interest to address it as soon as possible.

If the eRx status has a sent Status, usually after about 10 minutes, you can see any associated errors by doing the following:

  • Click on Maintenance > Setup > Prescriber Management.  The Prescriber Management window will open. 
  • Click on Message History (Bottom Right).  Insert the patient’s last name and click on Search. 
  • If the status is ‘Error,’ click on the eye icon on the right to open the raw message where you can find the denial reason. 
  • If you see no reason provided, it is more than likely that the refill request is out of the date scope for the pharmacy.  To rectify, remove the eRx from the medication list and make a new one.  You should have a new status in under 5 minutes. 

NOTICE: Any eRx refill request received in the Worklist that does not have a corresponding Medication in the current medications list will result in a pop-up box. To rectify the problem, you can match the refill request from the medication on the left to a medication in the drop-down list, OR you may deny the request and select the Proceed button. The pharmacy will receive a denial request. You may also deny the eRx now and submit a new medication.

If, after you perform these steps, you require further assistance, please call Sunrise Services Support line @ 502-538-4665.

Medisoft Clinical’s latest upgrade includes several other advancements to help in your staffs’ daily workflow.

A new Prior Auth button is available in the eRx Worklist: Click the ‘Prior Auth’ button to access the CoverMyMeds ePA Dashboard.  For more information on enrollment, contact Sunrise Services support.

When you discontinue medication and select either Adverse reaction or Allergic reaction as the discontinue reason, a new section expands to enter details about the reaction. Select the severity from the drop-down options and type or select the reaction description.

A CCDA based on selections clicked in the clinical summaries is now sent to Updox (Patient Portal). Make your selections within the Special Features section of the Configuration drop-down.

The most significant changes in the new RX process are behind the scenes.  No longer is Medisoft Clinical using the PMSI application, but rather the more stable PMSI Interoperability service. This change frees up memory and allows the program to operate at a premium level.

For additional information on Medisoft Clinical’s new features and how to incorporate them into your workflow, give Sunrise Service’s support team a call at (502) 538-4665.

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eClinicalWorks LLC to Pay $155 Million to Resolve Civil False Claims Act Allegations

eClinical Works has agreed to pay $155 million to resolve allegations the the EHR company misled consumers about the certification of it’s EHR technology and paid some customers kickbacks in return for positive promotion of it’s product, this is according to a press release by the Department of Justice May 31, 2017.

Since 2011, healthcare providers who used eClinical Works software and attested to satisfying the Meaningful Use objectives and measures received incentive payments through the Meaningful Use program. Had eClinical Works disclosed that its software did not meet the certification criteria, it would not have been certified and its customers would not have been eligible for incentive payments. In addition, requests for incentive payments that resulted from unlawful kickbacks constituted false claims.

eClinical Works paid unlawful remuneration to influential customers to recommend its product to prospective customer. Among other things, eClinical Works employed a “referral program” a “site visit program” and a “reference program”. Through its “referral program” eClinical Works paid current users as much as $500 for each provider they referred who executed a contract with eClinical Works. All of these programs violated the Anti-Kickback Statute and are included in the original complaint.

The company and its three founders — CEO Girish Navani, CMO Rajesh Dharampuriya, MD, and COO Mahesh Navani — will be responsible for paying $154.9 million to the federal government. One developer and two project managers are on the hook for a combined $80,000.

Under the settlement, the EHR company headquartered in central Massachusetts will enter into a five-year Corporate Integrity Agreement (CIA) with the Office of Inspector General (OIG), which includes a provision that eClinicalWorks “retain an Independent Software Quality Oversight Organization to assess ECW’s software quality control systems and provide written semi-annual reports to OIG and ECW documenting its reviews and recommendations.”

Customers of the EHR company will be able to obtain updated versions of eClinicalWorks at no cost or transfer their data to another EHR software free of charge.

 

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Advancing Care Information and Improvement Activities-Q&A

shutterstock_498951139The Merit Based Incentive Program (aka MIPS) defines four categories of eligible clinician performance, contributing to an annual MIPS final score of up to 100 points (relative weights are indicated for the CY2017 performance year and associated CY2019 payment year):

  • Quality (60% for 2017)
  • Advancing Care Information (ACI, renamed from Meaningful Use) (25% for 2017)
  • Improvement Activities (CPIA) (15% for 2017)
  • Cost (0% for 2017, but will be weighted for 2018 and beyond)

On December 13, 2016 the Centers for Medicare & Medicaid Services (CMS), briefly discussed two of the four Merit-based Incentive Payment System (MIPS) categories: Advancing Care Information (ACI) and Improvement Activities. Most of the 90-minute session was reserved for questions and answers. Here are some of the questions your colleagues asked, with answers from CMS.

Q: How is the ACI scored for hospital-based and non-facing patient clinicians who are part of a large multi-specialty reporting as a group?

A: That would depend on whether they choose to submit data, or not; they still have the option because they’re hospital-based. If they choose to participate, they will be scored as a group. The resulting update will apply to everybody in the group.

Q: When ACI is set to zero, to what category is the percentage applied?

A: The entire 25 points is moved to the Quality category, so instead of the Quality category being worth 60 points, it will be worth 85 points of the composite performance score (CPS).

Q: Will providers be submitting data through the same system for ACI and Improvement Activities as they did for the Electronic Health Record (EHR) Incentive Program?

A: No. There will be a new system for MIPS. However, if you are eligible to participate in the Medicaid EHR Incentive Program, you will need to attest through the same system as before.

Q: When reporting as a group, will nurse practitioners and physician assistants be excluded from ACI scoring if no data is submitted?

A: Yes. But if they are part of a group ,they will get the same update as everyone else in the group.

Q: Do eligible clinicians need to inform CMS in advance whether they will be attesting as an individual or a group? If so, how do they do that?

A: They don’t have to inform CMS; they just submit the data — unless they are reporting as a group through the CMS Web Interface or reporting Consumer Assessment of Healthcare Providers and Systems (CAHPS) data. Information on these protocols are forthcoming.

Q: For the test portion of Pick Your Pace, which allows for one improvement activity to receive credit, can we pick any activity or do we need to pick a high or medium activity?

A: You can pick a high or medium activity, but a medium activity will only give you have the points (7.5) toward your final score.

Q: If we do not use an EHR and cannot attest to ACI, do we have to attest or submit this fact anywhere?

A: No. Just don’t complete that part of the reporting requirements.

Q: The rule states that ACI performance for groups will be based on a group score. Does that mean the reports showing the numerator/denominator for each eligible clinician in the group have to be combined?

A: The attestation should be aggregate there is one submission — one numerator and denominator per measure — for the group. If the group is using multiple EHR technologies, you will have to sum the numerator/denominator for each measure across the different EHRs for the group.

Q: If you do group reporting, do you only need a “1” in the numerator for the entire group to get credit for the base score under ACI?

A: Yes.

Q: When will the specifics of the improvement activities be released? The working on the 90-plus activities are vague and open to interpretation.

A: We are not planning to issue more specific language around the activities for the transition year. We aren’t requiring any specific data to be submitted. What you see is on the Quality Payment Program (QPP) website is all that is required.

Q: Will the bonus payment be a one-time payment?

A: Whatever score you get in MIPS will be applied to your Physician Fee Schedule amount. The method for paying the added bonus for exceptional performers is still being worked out.

Q: What if your certified EHR technology (CEHRT) year changes mid year due to an upgrade and your submitting a full year of data?

A: You can submit a combination. Aggregate your data between the  two EHRs and submit the data for the ACI category as one submission. This is not the case for Quality reporting, however. You will need to work with a data aggression vendor to report electronic Clinical Quality Measures (eCQMs), in that case.

Q: Does MIPS reporting take the place of EHR reporting? Do we still have to use a qualified EHR or can we do claims-based reporting?

A: The data needs to come out of your EHR. For Quality measures, you’re no longer required to submit eCQMs to earn credit. In the Quality category, you could submit via claims and it wouldn’t count against you.

Q: Can you report as a group under MIPS if not all of your providers are using a CEHRT?

A: Yes.

Q: What type of documentation is required for improvement activities?

A: For improvement activities, we are not requiring documentation. But providers should retain copies of medical records, charts, reports, and any electronic records that are applicable and appropriate for up to 10 years after the conclusion of the performance period, in case of an audit.

See the whole presentation:

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CMS Announces July 2015 Transition from IACS to EIDM

CMS 

The Centers for Medicare & Medicaid Services (CMS) would like to inform Physician Quality Reporting System (PQRS) participants and their staff to an important system update scheduled to be in place on July 13, 2015.


The Individuals Authorized Access to CMS Computer Services (IACS) system will be retired, but current IACS user accounts will transition to an existing CMS system called Enterprise Identity Management (EIDM). The EIDM system provides a way for business partners to apply for, obtain approval, and receive a single user ID for accessing multiple CMS applications.


Existing PQRS IACS users, their data, and roles will be moved to EIDM and will be accessible from the ‘PQRS Portal’ portion of the CMS Enterprise Portal at  http://portal.cms.gov. Users will then access the PQRS Portal to submit data, retrieve submission reports, view feedback reports, or conduct various administrative and maintenance activities. New PQRS users will need to register for an EIDM account.


Stay tuned for more information and resources in the coming weeks and months! In the meantime, please ensure that your IACS account is active, current, and you’re able to log in. This will help ensure a smoother transition to EIDM.


For additional assistance regarding IACS or EIDM, contact the QualityNet Help Desk at 1-866-288-8912 (TTY 1-877-715-6222) from 7:00 a.m. to 7:00 p.m. Central Time Monday through Friday, or via email at qnetsupport@hcqis.org. To avoid security violations, do not include personal identifying information, such as Social Security Number or TIN, in email inquiries to the QualityNet Help Desk.

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CMS Announces Extension for EPs participating in PQRS via EHR and QCDR (QRDA III format)

The Centers for Medicare & Medicaid Services (CMS) is pleased to announce that the submission deadlines for the PQRS reporting methods below have been extended.  All other submission timeframes for other PQRS reporting methods remain the same.  The revised submission timeframes are:

Reporting Method Submission Period Submission Deadline Time

(All Times are Eastern)

EHR Direct or Data Submission Vendor that is certified EHR technology (CEHRT) 1/1/15 – 3/20/15 8:00 p.m.
Qualified clinical data registries (QCDRs) (using QRDA III format) reporting for PQRS and the clinical quality measure (CQM) component of meaningful use for the Medicare Electronic Health Record (EHR) Incentive Program 1/1/15 – 3/20/15 8:00 p.m.

An Individuals Authorized Access to CMS Computer Services (IACS) account with the “PQRS Submitter Role” is required for these PQRS data submission methods. Please see the IACS Quick Reference Guides for specifics.

PQRS provides an incentive payment to individual eligible professionals (EPs) and group practices that satisfactorily participate or satisfactorily report data on quality measures for covered Medicare Physician Fee Schedule (PFS) services. Additionally, those who do not meet the 2014 PQRS reporting requirements will be subject to a negative payment adjustment on all Medicare Part B PFS services rendered in 2016.

Note:  The deadline listed above does apply to Individual Eligible Professionals and Group Practices participating in other CMS programs such as the Medicare EHR Incentive Program and Comprehensive Primary Care Initiative that are utilizing the reporting methods listed above. Additionally, CMS has extended the deadline for EPs wishing to attest to meaningful use for the EHR reporting period in 2014 for the Medicare Electronic Health Record (EHR) Incentive Program to March 20, 2015. Please be on the lookout for a separate listserv with information regarding the attestation extension.

For questions, please contact the QualityNet Help Desk 1-866-288-8912 or via email at Qnetsupport@hcqis.org from 7:00 a.m. – 7:00 p.m. Central Time. Complete information about PQRS is available at  http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/index.html.

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Using templates in your EHR? Make sure they are updated for ICD-10!

The follow article, written by Cathie Wilde pertains to any EHR that is “template driven”.  As we approach (hopefully) adoption of ICD-10 codes, looking at how your templates are coded is one of those great first steps a practice can take to begin it’s transition to ICD-10.

 Published from ICD-10 monitor:
 “Templates can either enhance documentation necessary for coding and data quality, or they can hinder things by restricting options and failing to prompt physicians to document specific information. However, templates cannot be overlooked when it comes to ICD-10. This is particularly true if a hospital relies more heavily on templates to capture structured data. Many hospitals may use templates for certain diagnoses, orders, or visit types and allow physicians to dictate information for everything else.

Regardless of a hospital’s specific use of templates, one point remains clear: the templates must be updated to accommodate the details necessary for ICD-10. At a minimum, these details include laterality, specificity, and etiology. The number of physicians who could be using a specific template at any given time — or even over a short period of time — could be significant. If one template is not updated correctly to accommodate ICD-10, data quality and reimbursement could be compromised.

Health information management (HIM) directors cannot assume that electronic health record (EHR) vendors will handle this effectively and in a timely manner. Instead, take the following steps to ensure that all updates will be made:

1. Take an inventory of all current templates in use. Are some of these templates used more frequently than others? Can any of them be retired if not in use? Ask for input from coders — what information is typically missing from the templates? Can you add or revise this information during the ICD-10 update? Work with your EHR vendor to make these changes before tackling ICD-10 updates.

2. Form a committee to address ICD-10 template updates. This committee, which can be a subcommittee of the ICD-10 implementation committee, should include coders, clinical documentation improvement (CDI) specialists, a physician champion, and an EHR representative. Compile a list of all diagnoses and procedures that require greater specificity in ICD-10 and cross-check this list with any templates that are in use. Ensure that each and every reference to these diagnoses and procedures is updated to accommodate ICD-10 specificity and other requirements.

3. Tie your template update efforts to your query update efforts. As CDI specialists review queries to ensure the implementation of updates for ICD-10, they can easily use this information to review templates in light of ICD-10 changes. If templates ultimately capture all of the relevant information that coders need, a query may not even be necessary.

4. Review templates after updates have been made. Set a deadline for all template updates to be completed. Then manually review each template to ensure that updates have been entered correctly.

5. Educate physicians. Physicians don’t need template-specific training; however, let physicians know that the updated templates exist when performing specialty-specific ICD-10 training. Reiterate that the templates exist to make physicians’ jobs easier by prompting them to document what’s necessary and pertinent to ICD-10 in the most concise way.

Clinical areas for review

Consider focusing on the following templates that require new and more specific documentation in ICD-10:

Obstetrics-related templates

  • Specific trimester: The majority of codes in Chapter 15 (Pregnancy, Childbirth, and the Puerperium) feature a final character that indicates the trimester of the pregnancy. Assignment of this character is based on the provider’s documentation of the patient’s trimester during the admission/encounter. Templates should include the weeks of gestation at the time of admission and/or delivery.
  • Fetus identification: ICD-10 requires a seventh character to denote multiple gestations, when applicable. This character identifies the fetus for which the complication code applies. Templates should provide an option for this character.
  • Multiple gestation placenta status: ICD-10 features a combination code for multiple gestation and identification of the number of placentas and amniotic sacs. Templates should capture this information as well.

Trauma-related templates

  • Glascow coma scale: This scale denotes the degree of consciousness and is used commonly with head trauma cases. The score can function as an indicator for testing or treatment as well as predict the duration and outcome of the coma. Templates for head injuries should specifically include this information.
  • Gustilo classification: This classification applies to open fractures of the long bones, including the humerus, radius, ulna, femur, tibia, and fibula. The classification system groups open fractures into three main categories and three subcategories defined by these characteristics: mechanism of injury, extent of soft tissue damage, and degree of bone injury or involvement. Templates for open fractures should include this information.
  • Salter-Harris classification: This classification includes nine types of fractures that occur along the epiphyseal (growth) plates in bones that have not reached full maturity. With these types of fractures, plates are still open and filled with cartilaginous tissue. These fractures are common among children. Templates for these fractures should include information related to the Salter-Harris classification system.

Wound-related templates

  • Severity: In addition to specific location and etiology of non-pressure skin ulcers, ICD-10 also requires physicians to document the severity of the ulcer as follows:
    • Limited to breakdown of skin
    • With fat layer exposed
    • With necrosis of muscle
    • With necrosis of bone

Any and all wound templates should include these designations. Pressure ulcer templates should continue to include the stage of the ulcer.

Nutrition templates

  • Obesity: In addition to the current body mass index documentation on nutrition orders/templates for obesity, ICD-10 includes additional codes for obesity due to excess calories, drug-induced obesity, and morbid obesity with alveolar hypoventilation. Templates should be updated to include these designations. “

About the Author

Cathie Wilde, RHIA, CCS, is the director of coding services for MRA. Ms. Wilde has been active in the healthcare industry for more than 30 years. Her previous positions have included assistant director of HIM, DRG coordinator at the Massachusetts Hospital Association, and DRG validator at Blue Cross Blue Shield. She has extensive experience in ICD-9-CM and CPT coding, auditing, data analysis, development and testing of coding products, specialized reporting, and in-service training. As director she is responsible for overseeing the coding division, providing the strategic direction of MRA as a local industry leader of quality coding, auditing, and denial management services. Ms. Wilde is an American Health Information Management Association (AHIMA)-approved ICD-10-CM/PCS trainer.

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New CMS rule allows flexibility in certified EHR technology for 2014

The Department of Health and Human Services (HHS) published a final rule on August 29, 2014, that allows health care providers more flexibility in how they use certified electronic health record (EHR) technology (CEHRT) to meet meaningful use for an EHR Incentive Program reporting period for 2014. By providing this flexibility, more providers will be able to participate and meet important meaningful use objectives like drug interaction and drug allergy checks, providing clinical summaries to patients, electronic prescribing, reporting on key public health data and reporting on quality measures.

“We listened to stakeholder feedback and provided CEHRT flexibility for 2014 to help ensure providers can continue to participate in the EHR Incentive Programs forward,” said Marilyn Tavenner, CMS administrator. “We were excited to see that there is overwhelming support for this change.”

Based on public comments and feedback from stakeholders, the Centers for Medicare & Medicaid Services (CMS) identified ways to help eligible professionals, eligible hospitals, and critical access hospitals (CAHs) implement and meaningfully use Certified EHR Technology. Specifically, eligible providers can use the 2011 Edition CEHRT or a combination of 2011 and 2014 Edition CEHRT for an EHR reporting period in 2014 for the Medicare and Medicaid EHR Incentive Programs; All eligible professionals, eligible hospitals, and CAHs are required to use the 2014 Edition CEHRT in 2015.

These updates to the EHR Incentive Programs support HHS’ commitment to implementing an effective health information technology infrastructure that elevates patient-centered care, improves health outcomes, and supports the providers that care for patients.

The rule also finalizes the extension of Stage 2 through 2016 for certain providers and announces the Stage 3 timeline, which will begin in 2017 for providers who first became meaningful EHR users in 2011 or 2012.

See the full press release here:  http://cms.gov/Newsroom/MediaReleaseDatabase/Press-releases/2014-Press-releases-items/2014-08-29.html

See the EHR Incentive Programs 2014 CEHRT Ruke: Quick Guide here:  http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/CEHRT2014_FinalRule_QuickGuide.pdf

See the CEHRT Flexibility Decision Tool here:  http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/CEHRT_Rule_DecisionTool.pdf

Kelly Meeks

Sunrise Services, LLC

http://www.sunrize.com

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New EHR Attestation Deadline

New EHR Attestation Deadline for Eligible Professionals:
March 31, 2014

CMS is extending the deadline for eligible professionals to attest to meaningful use for the Medicare EHR Incentive Program 2013 reporting year from 11:59 pm ET on February 28, 2014 to 11:59 pm ET March 31, 2014.
In addition, CMS is offering assistance to eligible hospitals who may have experienced difficulty attesting to submit their attestation retroactively and avoid the 2015 payment adjustment.
This extension will allow more time for providers to submit their meaningful use data and receive an incentive payment for the 2013 program year, as well as avoid the 2015 payment adjustment.
This extension does not impact the deadlines for the Medicaid EHR Incentive Program or any other CMS program, including the electronic submission for the Physician Quality Reporting System EHR Incentive Program Pilot.

How to attest?
If you are an eligible professional, you may use the registration and attestation system to submit your attestation for meaningful use for the 2013 reporting year. You must attest prior by 11:59 pm ET on March 31, 2014 to meet the new 2013 program deadline.
If you are an eligible hospital, you may contact CMS for assistance submitting your attestation retroactively. You must contact CMS by 11:59 pm on March 15, 2014 in order to participate for the 2013 program year.

Resources
If you are an eligible professional working on your attestation for the 2013 reporting period, there are resources available to help you with the registration and attestation process.
Stage 1 Meaningful Use Calculator
Registration and Attestation User Guides
EHR Incentive Program Website
The EHR Information Center is open to assist you with all of your registration and attestation system inquiries. Please call, 1-888-734-6433 (primary number) or 888-734-6563 (TTY number). The EHR Information Center is open Monday through Friday from 7:30 a.m. – 6:30 p.m. (Central Time), except federal holidays.

Tips
In addition, there are some simple steps you can take which will help to make the process easier for you:
• Ensure that your payment assignment and other relevant information is up to date in the Medicare payment system PECOS
• Make sure to include a valid email address in your EHR program registration
• Consider logging on to use the attestation system during non-peak hours such as evenings and weekends
• Log on to the registration and attestation system now and ensure that your information is up to date and begin entering your 2013 data
• If you experience attestation problems, call the EHR Incentive Program Help Desk and report the problem
• If your organization has more than 1,000 providers assigned to a proxy user, use the PECOS system to designate additional proxies to facilitate attestation.

Eligible Hospital Instructions:
1. Send the following information to EH2013Extension@Provider-Resources.com no later than 11:59 PM EST on 3/15/2014:
o CCN
o Hospital Name
o Contact Person Name
o Contact Person Email
o Contact Person Phone
2. Type “EH 2013 EXTENSION” in the subject line of the email note
3. Each Hospital must be identified in a separate email
CMS will contact the person that you designate in your request to provide additional instructions regarding the Eligible Hospital 2013 attestation submission.

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How to Prepare For, Survive an EHR Meaningful Use Audit

Posted from AAFP News Now:

Use of the words “audit” and “Medicare” in the same sentence tend to make even the most seasoned physician uncomfortable. So when the news broke in March that CMS had added prepayment meaningful use (MU) audits to its ongoing postpayment audit process, some family physicians expressed concern.

Understanding that a little knowledge can go a long way toward alleviating anxiety, AAFP News Now recently spoke with a government expert about how physicians can prepare for MU audits associated with the Medicare Electronic Health Records (EHR) Incentive Program.

Rob Anthony, deputy director of the Health IT Initiatives Group for CMS’ Office of E-Health Standards and Services, noted that as many as 10 percent of program participants would face an audit. “Keep in mind that the audits are both random and targeted,” said Anthony, so physicians shouldn’t assume they’ve made an error if they receive an e-mail audit notification from Figliozzi and Co., the certified public accountant firm selected by CMS to conduct the audits.

“We’re required to do due diligence on our end,” said Anthony, and that includes robust oversight of a government program that disperses taxpayer dollars in the form of physician bonuses that can total as much as $18,000. According to Anthony, the audit process is the same regardless of whether physicians are notified before or after they are issued a check for successfully meeting MU program requirements.

“The first thing we always tell people is that if you’ve entered accurate numbers (in the MU attestation process) and have the documentation to support that, then the audit is a really simple process for this program. You’re simply showing (auditors) supporting documentation,” said Anthony.

For the vast majority of people, the primary support document is the report generated by a certified EHR because it generally provides both the numerator and denominator values needed for MU attestation.

“It’s important to make sure the report specifies a time period and indicates that it is specific to you as a provider,” said Anthony. That’s as easy as including a National Provider Identifier, provider name or practice name.

Anthony noted that some certified EHRs provide a “snapshot in time,” meaning that the physician can go back to any 90-day period, and the system always shows the correct numerator and denominator values for that period. However, many EHRs don’t have that function and instead use what Anthony called a “rolling system” that changes the values of the numerators and denominators after the reporting period ends.

In that situation, he advised physicians to “save either a paper or an electronic copy of the report you used to attest so that when an auditor comes knocking and asking for supporting documentation, you can hand him a report that shows the numerator and denominator values that you entered (for attestation) rather than something that might have changed later down the line.”

A number of physicians also have had trouble complying with what Anthony called the “yes/no functionality issues” that require specific EHR functions — such as drug allergy interaction checks and clinical decision support — to be turned on during the entire reporting period.

“Some systems have an audit log that shows that you have functionality enabled for the entire reporting time, but many systems don’t,” said Anthony. If your system doesn’t, save one or more screen shots that are dated from the reporting period to which you are attesting.

One additional area that has snagged numerous physicians is the security risk analysis. “This doesn’t impose any additional requirements beyond what’s already required for a security risk analysis for your practice as part of HIPAA (the Health Insurance Portability and Accountability Act),” said Anthony. “The only difference is that we require it more frequently,” or every year for MU versus every two years for HIPAA purposes.

Anthony warned that a “generalized” security risk analysis wouldn’t meet the MU audit requirement. “You need something that shows it (an analysis) was done before the end of the reporting period and that shows it is specific to your certified EHR and your particular practice. Information that is dated and specific to you goes a long way for a lot of these requirements.”

Lastly, Anthony advised physicians to direct any audit questions to Figliozzi and Co., including requests for clarification about requested documents as well as requests for additional time to comply.

Anthony summed up how to make the audit process go smoothly: “If you’ve input the numbers correctly and accurately, and you have the documentation to show how you got there, the audit process is simple. You’re not generating new information.”

Additional resources can be found by clicking the following links:

CMS: EHR Incentive Program Supporting Documentation for Audits

CMS: Audit Overview Fact Sheet

CMS: Sample Audit Request Letter