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New EHR Incentive Program FAQs from CMS

On October 6, the Centers for Medicare & Medicaid Services (CMS) released the final rule with comment for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. To keep you informed of changes to the programs and how to participate in 2015, CMS has also released three new FAQs providing clarification on how to attest to certain measures for health information exchange, patient electronic access, and other objectives that require patient action.

FAQ 12817
Question: For the Health Information Exchange objective for meaningful use in 2015 through 2017, may an eligible professional (EP), eligible hospital or critical access hospital (CAH) count a transition of care or referral in its numerator for the measure if they electronically create and send a summary of care document using their CEHRT to a third party organization that plays a role in determining the next provider of care and ultimately delivers the summary of care document?

Answer: Yes. An EP, eligible hospital or CAH may count transmissions in this measure’s numerator when a third party organization is involved so long as:

  • The summary of care document is created using certified EHR technology (CEHRT);
  • The summary of care document is transmitted electronically by the EP, eligible hospital or CAH to the third party organization…read the full FAQ.

FAQ 12821
Question: If multiple eligible professionals or eligible hospitals contribute information to a shared portal or to a patient’s online personal health record (PHR), how is it counted for meaningful use when the patient accesses the information on the portal or PHR?

This answer is relevant to the following meaningful use objectives: Patient Specific Education and Patient Electronic Access measure 2.

Answer: If an eligible professional sees a patient during the EHR reporting period, the eligible professional may count the patient in the numerator for this measure if the patient (or an authorized representative) views online, downloads, or transmits to a third party any of the health information from the shared portal or online PHR. The same would apply for an eligible hospital or CAH if a patient is discharged during the EHR reporting period. If patient-specific education resources are provided electronically, it may be counted in the numerator for any provider within the group sharing the CEHRT who has contributed information to the patient’s record if that provider has the patient in their denominator for the EHR reporting period. The respective eligible professional, eligible hospital, or CAH must have contributed at least some of the information identified in the Medicare and Medicaid Programs; Electronic Health Record Incentive Program – Stage 3 and Modifications to Meaningful Use in 2015 Through 2017 final rule (80 FR 62807 through 62809) to the shared portal or online PHR for the patient. However, the respective provider need not have contributed the particular information that was viewed, downloaded, or transmitted by the patient. …Read the full FAQ.

FAQ 12825
Question: In calculating the meaningful use objectives requiring patient action, if a patient sends a message or accesses his/her health information made available by their eligible professional (EP), can the other EPs in the practice get credit for the patient’s action in meeting the objectives?

Answer: Yes. This transitive effect applies to the Secure Electronic Messaging objective, the 2nd measure of the Patient Electronic Access (View, Download and Transmit) objective, and the Patient Specific Education objective.

If a patient sends a secure message about a clinical or health related subject to the group practice of their EP, that patient can be counted in the numerator of the Secure Electronic Messaging measure for any of the EPs at the group practice who use the same certified electronic health records technology (CEHRT) that saw and patient during their EHR reporting period.

Similarly, if a patient views, downloads or transmits to a third party the health information that was made available online by their EP, that patient can be counted in the numerator of the 2nd Patient Electronic Access measure for any of the EPs in that group practice who use the same CEHRT and saw that patient during their EHR reporting period.

If patient-specific education resources are provided electronically, it may be counted in the numerator for any provider within the group sharing the CEHRT who has contributed information to the patient’s record if that provider has the patient in their denominator for the EHR reporting period. … Read the full FAQ.

For more information on accurately calculating the numerator for measures, please visit FAQ 8231.

November 10, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

New Certified Health IT Mark from ONC

One of the keys to a good certification is good branding. Think about JD Power and Associates. When you see that brand, you know what it means and what it represents. For EHR software, ONC is likely hoping that their new ONC Certified HIT mark will do something similar for EHR software.

Here’s the mark you should look for to know if an EHR meets the 2014 Edition Standards and Certification criteria:
ONC EHR Certification - Health IT Mark

What’s in a mark? I think it currently serves two purposes. First, it says if that EHR vendor can help you show meaningful use and get the EHR incentive money. This is the most important part of a good mark. The second is that EHR vendors that have this mark will have conformed to the interoperability standards that are set in the EHR certification process. I’m hopeful that this is the most valuable thing that comes out of EHR certification and meaningful use.

The following is the full press release from HHS about the new EHR certification mark.

EHR products must meet standards and certification criteria to be certified

A new mark for certified electronic health records (EHR) technology was unveiled today by the HHS Office of the National Coordinator for Health Information Technology (ONC). The mark will appear on EHR products that have been certified by an ONC-Authorized Certification Body (ONC-ACB) and will indicate that the product meets the 2014 Edition Standards and Certification Criteria.

Eligible professionals and hospitals must demonstrate meaningful use of EHR technology that has been certified under the ONC Health Information Technology (HIT) Certification Program to qualify for Medicare and Medicaid EHR incentive payments.

“We’ve reached the tipping point of doctors adopting electronic health record systems and using them to improve patient care,” said Farzad Mostashari, M.D., national coordinator for health information technology. “The use of the ONC Certified HIT mark will help to assure them that the EHR they have purchased will support them in meeting the Meaningful Use requirements.”

Electronic health records technology may be certified by one of four ONC-ACBs accredited by the American National Standards Institute (ANSI) and authorized by ONC. The mark is a visual cue that the product – whether a complete EHR, an EHR module or another type of health IT product – meets ONC’s applicable certification criteria and can achieve interoperability, functionality and security. For example, the criteria include such requirements as computerized provider order entry (CPOE), drug to drug and drug-allergy checks, and the capability to coordinate clinical information to help improve the quality of patient care, among others.

When the mark is associated with a certified “Complete EHR” it means that the EHR technology can be used without modification to achieve Meaningful Use. A certified EHR module may be combined with other modules to make a complete system. Some modules may include the ability to:

  • ·         Create a standard patient summary care record;
  • ·         Securely transmit summary care records using Direct, a tool created through an ONC-led collaboration with broad health IT industry participation, that allows for the secure exchange of health information over the Internet; and
  • ·         Provide patients with online access to view, download, and transmit their health information to destinations of their choice.

ONC-ACBs will begin to issue the mark to certified EHR products immediately. To learn more about the terms and use of the mark, click here.

July 11, 2013 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

EHR Certification Revoked for EHRMagic

Yesterday HHS released news that they’d revoked the EHR certification of the EHRMagic-Ambulatory and EHRMagic-Inpatient EHR software. Looks like InoGard originally certified the EHR and they and ONC received information that had them retest the EHR software and it failed the certification re-test.

I think we all want government to hold bad actors accountable. So, it’s good to weed out EHR companies that aren’t doing what they should. However, they better also be careful. Imagine being a doctor of an EHR vendor whose EHR certification gets revoked. Does that mean that they have to give back the EHR incentive money the received? Those doctors trusted in InfoGard’s ability to certify an EHR vendor and InfoGard failed at that job. Should a doctor be punished for InfoGard’s failing? Now apply this to a hospital that uses a certified EHR and loses that EHR certification. That’s a multi-million dollar impact.

I guess EHRMagic better take down the info on their website that says they can get physicians $44,000 in EHR incentive money. Looking at their website, it makes me wonder who chose to use their EHR in the first place. That would be interesting to know.

Here’s the full press release from HHS on the EHR revocation:

Two electronic health records, previously certified as products to be used as part of the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs, have had their certifications revoked. Farzad Mostashari, M.D., the national coordinator for health information technology, announced today that the products do not meet standards and providers cannot use these products to meet the requirements of the Medicare and Medicaid EHR Incentive programs.

EHRMagic-Ambulatory and EHRMagic-Inpatient, both developed by EHRMagic Inc. of Santa Fe Springs, Calif., no longer meet the EHR certification requirements. The EHRs must be certified by a certification body (ACB) authorized by the Office of the National Coordinator for Health IT (ONC) before regaining certification.

Both ONC and an ONC ACB, InfoGard Laboratories Inc. (InfoGard), received notifications that the EHRMagic products did not meet the required functionality and the products should not have passed certification. InfoGard analyzed the additional information from the notification and contacted EHRMagic, launching the ONC authorized certification body required surveillance activities. InfoGard concluded that it was necessary for the EHR products to be retested for select requirements. EHRMagic, Inc. participated in retesting and failed.

“We and our certification bodies take complaints and our follow-up seriously. By revoking the certification of these EHR products, we are making sure that certified electronic health record products meet the requirements to protect patients and providers,” said Dr. Mostashari. “Because EHRMagic was unable to show that their EHR products met ONC’s certification requirements, their EHRs will no longer be certified under the ONC HIT Certification Program.”

Information about ONC’s certification process for EHR technologies is available at http://www.healthit.gov/providers-professionals/certification-process-ehr-technologies.

April 26, 2013 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Meaningful Use Attestation Deadline for 2012 and MU Stage 2 Testing Ready

Eligible professionals (EPs) who participated in the Medicare Electronic Health Record (EHR) Incentive Program in 2012 must complete attestation for the 2012 program year by February 28, 2013. In order to be eligible to attest you must have completed your 2012 reporting period by December 31, 2012.

CMS encourages Medicare EPs to register and attest as soon as possible to resolve any potential issues that may delay their payment.

Medicaid EPs should check with their State for their attestation deadline.

Resources from CMS
CMS has several resources located on the EHR Incentive Programs website to help EPs properly meet meaningful use and attest, including:

Also, for EHR vendors, ICSA just announced that they are now set to begin testing EHR software for meaningful use stage 2. That’s right. Meaningful Use stage 2 is just around the corner.

January 16, 2013 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

The Impact of EHR Certification

In the comments of my post on EMR and EHR titled EHR Vendors Using EHR Certification Excuse, Jeff offered a frank comment about the realities EHR vendors face in this current climate:

I went through EHR certification for a EHR product – for the sake of this discussion it can remain nameless as you can insert any EHR name and it will share the same issues. The process was cumbersome and I agree is not worthwhile for our clients. However at least 90% of our clients were requesting it and all of our sales pipelines say they required it. The interaction you describe I have had. I don’t think it’s the fault of us as a vendor as much as the short sightedness of the committee that created the certification rules. We had to implement fields/screens/buttons that served no purpose in the type of practice we supplied our software to. That did not matter to the certification proctor, we had to show it or we failed and lost a lot of money. Getting certified threw off our development cycle at least 6 months. During that time we had to push off many good customer requested enhancements. In hindsight would our customers prefer we did not get certified – probably, but could our company take a chance at not being able to renew contracts or get new sales. No way, not for a government mandated push.

This reminds me of a video I recently saw that asked the question, “What do we want EHR certification to do?” The problem here is that I think everyone has a different answer to that question. Until we define what EHR certification should really accomplish, it’s hard to make criteria that are beneficial and easy to understand. In the rush to meet the regulatory requirements I think we missed creating the bigger vision of why we’re doing EHR certification at all. That’s why we’re where we’re at today.

October 24, 2012 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

PDR Certified Help to Determine EHRs That Meet Minimum Drug Safety Requirements

A new drug safety certification program for EHR and ePrescribing platforms that is supposed to “recognize EHRs that meet minimum drug safety requirements” is in the works, according to a recent press release.

PDR Network, the leading distributor of FDA-approved drug labeling, safety and REMS information, and iHealth Alliance, a not-for-profit organization involved in protecting patients and providers, announced the program, “PDR Certified”, on May 10th. Healthcare providers will be able to determine if the EHR system they use currently or will be purchasing meets minimum drug safety requirements.

Because of the influx of EHRs in recent years, it is more important than ever for there to be certain requirements that must be met to ensure patient and provider safety. Nancy Dickey, the chair of the iHealth Alliance said concerning this:

It is vitally important that these systems include standards for drug safety functionality, and that these standards are easy for busy physicians to identify and understand — fortunately, these goals are shared widely and are in sync with those called for by the FDA.

In order for an EHR vendor to be considered “PDR Certified”, the following functions and features must be included in their product:

1. Full FDA Labeling

2. Drug Alerts and Warnings (Safety Alerts, Boxed Warnings, Recalls and REMS Communications)

3. Adverse Drug Event Reporting

4. FDA-compliant patient education or support services.

Any EHR vendor that becomes “PDR Certified”  can display the logo for “PDR Certified”, which will allow prospective and exisiting customers the opportunity to know they meet requirements above. Dr. David Troxel, Medical Director of the Doctors COmpany, said:

Access to full FDA labeling combined with timely delivery of drug alerts is critical to drug safety in any enviornment but particularly in EHRs which play such a large and growing role in care delivery today. PDR Certification will provide an easy to recognize way for our physician members, and all U.S. providers, to know if they system they are using or evaluating lives up to these drug safety standards.

More information on the program can be found at www.PDRCertified.org.

What do you think of having an EHR Drug Safety certification?

June 15, 2012 I Written By

Katie Clark is originally from Colorado and currently lives in Utah with her husband and son. She writes primarily for Smart Phone Health Care, but contributes to several Health Care Scene blogs, including EMR Thoughts, EMR and EHR, and EMR and HIPAA. She enjoys learning about Health IT and mHealth, and finding ways to improve her own health along the way.

Meaningful Use Stage 2 Comment Period Ends May 7th

ONC and CMS sent out the following email about the meaningful use stage 2 comment period. It closes very soon and so I encourage everyone to submit their comments on meaningful use stage 2. I’m a real proponent of the benefits of crowd sourcing and if enough people comment on meaningful use stage 2, I think we’ll receive the benefits of the crowd participating in the discussion and improving MU stage 2. I encourage doctors in particular to share their comments on the meaningful use stage 2 NPRM.

Please note that the comment period closes on Monday, May 7 for the notices of proposed rule-making (NPRMs) for Stage 2 of meaningful use and updated certification criteria.

The Office of the National Coordinator for Health IT (ONC) rule proposes the capabilities and related standards and implementation specifications that Certified EHR Technology will need to include to, at a minimum, support the achievement of “meaningful use” by eligible health care professionals beginning with the EHR reporting periods in FY/CY 2014. The rule also proposes revisions to the permanent certification program for health information technology, which include changing the name of the program to the “ONC HIT Certification Program.”

ONC’s rule complements the newly released Centers for Medicare & Medicaid Services (CMS) proposed rule for Stage 2 of the EHR Incentive Programs, clarifying the specifications necessary to meet the criteria for these programs.

Comments Can Be Submitted in 4 Ways

Both ONC and CMS rules identify that comments can be officially submitted in 4 ways:

  1. Electronically through www.regulations.gov – this is the preferred method
  2. Regular mail
  3. Express mail or overnight mail
  4. Hand-delivered/courier

Faxes are not accepted.

To enhance the public comment experience, ONC and CMS have made a copy of the rule available in Microsoft Word to make it easier those who comment to access and copy portions of their proposed rule for use in their individual comments.  Visit http://www.healthit.gov/providers-professionals/meaningful-use-stage-2 for more information.

May 4, 2012 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Quality Improvement Organization Gets Software ONC-ATCB Certified

I’ve been really fascinated to see all the various companies that are becoming ONC-ATCB certified software. I use to call it ONC-ATCB certified EHR, but with all these health IT companies becoming certified I don’t think we should be calling them EHR. They certainly support and connect with EHR software, but they aren’t EHR software per se.

I previously posted about a Data Warehouse Company being ONC-ATCB certified and a Patient Portal Achieving ONC-ATCB Certification. Both interesting use cases for achieving ONC-ATCB certification.

A few weeks ago it was announced that the Massachusetts eHealth Collaborative (MAeHC) has certified their Quality Data Center (QDC) software. As I understand it, MAeHC is a quality improvement organization which makes for another interesting entry into the ONC-ATCB certification space. They seem to have a lot of connections with REC organizations which will be interesting as well.

When you look through the list of requirements that MAeHC met it basically met the required security criteria and then the clinical quality measures. I imagine the real benefit of using this software is for those trying to combine data from multiple EHR systems. I wonder which type of organization we’ll see becoming ONC-ATCB certified next.

December 21, 2011 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Permanent EHR Certification Program (ONC-ACB) Delayed – Is Meaningful Use Stage 2 Delay Next?

It doesn’t come as much of a surprise to me to see the news (yes it’s a couple days old now) that the permanent EHR certification program (where ONC-ATCB becomes ONC-ACB) has been delayed. It was set to sunset at the end of this year and it would essentially convert into the permanent EHR certification program.

ONC’s Farzad Mostashari put out a letter describing the delay in implementing the permanent EHR certification program in this letter. Here’s one portion of the letter:

ONC pushed the plan back after it consulted with the American National Standards Institute (ANSI), which ONC selected as its approved accreditor (ONC-AA) earlier this year, and the National Institute of Standards and Technology (NIST), which administers the National Voluntary Laboratory Accreditation Program (NVLAP). ANSI and NIST said they needed more time to complete the approval of testing labs and certification organizations and ONC to review the applications of the certifiers.

Part of the reasoning for this was for the permanent EHR certification to coincide with the final rule for meaningful use stage 2. I guess it makes sense.

The real challenge I have when thinking about the change from temporary to permanent status is, what will really change? To me this feels mostly like a bureaucratic requirement as opposed to some change that actually provides some sort of benefit.

Will an ONC-ACB provide something of more value than a ONC-ATCB does now? I think not. Will EHR vendors go through a different process with an ONC-ACB compared with what they do now with the ONC-ATCB? I can’t imagine they will. Seems the only ones that should be concerned with this are the ONC-ATCB’s.

Plus, if meaningful use stage 2 gets delayed, then will the permanent EHR certification get delayed again too? Now your ears perk up. Not because anyone cares about the permanent EHR certification, but because a delay in meaningful use stage 2 would be something of note.

November 4, 2011 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Patient Portal Meets Meaningful Use ONC-ATCB Certification Requirements

It’s been really interesting to see all the companies that are going after the ONC-ATCB EHR Certification. As one person mentioned to me this weekend, an EHR vendor that isn’t an ONC-ATCB certified EHR is dead in the water. With a few minor exceptions, that’s absolutely true. So far though, every EHR vendor that I know of has or will be an ONC-ATCB certified EHR.

Something that I’ve found really intriguing is all the modular EHR certified software products that have come out. Often these modular EHR certifications represent interesting companies or product lines for large companies that I never knew about.

I previously posted about a data warehouse product achieving the modular EHR certification. Today I saw that GE Centricity’s Patient Portal has achieved modular EHR certification as well. In many cases it makes a lot of sense to have the patient portal from a separate company. Particularly when you have multiple EHR software. So, it’s nice you can use it without worrying about the EHR certification since they are now certified.

I’ll be interested to see what other modular EHR certifications come out.

October 6, 2011 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.