I wish I could come up with the definitive answer to this question. Inside our firm, and across our subscriber base, we engage in stimulating discussion on the topic. Based on relevant CMS publications (appended to the end of this article) a reasonable person could come up with either of the following interpretations:
Interpretation 1: It will not be acceptable to rely on the fact you are using a certified EHR. Accuracy is the responsibility of the provider, not the vendor.
Interpretation 2: If the Certified EHR generates a number, CMS will deem the number to be accurate.
Of course, those of us with products or services to sell will try to drive you to Interpretation 1. That perspective points out that definitions of patient population for numerators and denominators has, in some cases been changed (or at least clarified) by CMS pronouncement after the issuance of NIST testing procedures for certifying EHR software. And further, those test procedures do not explicitly provide an ATCB with the detail calculations of Meaningful Use Measures and Quality Measures, under all assumptions and choices a provider might make (i.e., there are some instances of CPOE that should not be counted if entered by an individual inappropriate to the CMS regulations, or our hospital has chosen to count only Observation Services Patients). Under this interpretation, prudence dictates at least a modest testing program against patient-level detail to validate the completeness and accuracy of each report.
Under Interpretation 2, comes the reasonable assumption that CMS today relies on their testing processes to certify software. And that for the next six years (period open for audit), that interpretation will be consistently applied.
To provide some context for these interpretations, let's consider CPOE. For Hospital A (or EP A), let's assume the certified EHR reports 32%, which is above the 30% threshold. Further, CMS states that each provider must to evaluate on a case-by-case basis whether a given situation is entered according to state, local, and professional guidelines, allows for clinical judgment before the medication is given, and is the first time the order becomes part of the patient's medical record. So one logical extension (relative to EHR reports,then) is that providers should also evaluate the reporting from their EHR as to compliance with the regulatory processes in their environment.
So, rather than apply more of my interpretations, here's the CMS FAQ defining the issue. This is also part of the statements you'll agree to during the registration and attestation processes. Take a look, and share your thoughts ... which interpretation shall drive your efforts?
Published 04/22/2011 01:58 PM | Updated 04/26/2011 05:48 PM | Answer ID 10589
To what attestation statements must an eligible professional (EP), eligible hospital, or critical access hospital (CAH) agree in order to submit an attestation, successfully demonstrate meaningful use, and receive an incentive payment under the Medicare Electronic Health Record (EHR) Incentive Program?
Currently, the attestation process requires EPs, eligible hospitals, and CAHs to indicate that they agree with the following attestation statements:
- The information submitted for clinical quality measures (CQMs) was generated as output from an identified certified EHR technology.
- The information submitted is accurate to the knowledge and belief of the EP or the person submitting on behalf of the EP, eligible hospital, or CAH.
- The information submitted is accurate and complete for numerators, denominators, exclusions, and measures applicable to the EP, eligible hospital, or CAH.
- The information submitted includes information on all patients to whom the measure applies.
CMS considers information to be accurate and complete for CQMs insofar as it is identical to the output that was generated from certified EHR technology. Numerator, denominator, and exclusion information for CQMs must be reported directly from information generated by certified EHR technology. By agreeing to the above statements, the EP, eligible hospital, or CAH is attesting that the information for CQMs entered into the Registration and Attestation System is identical to the information generated from certified EHR technology.
CMS does not require EPs, eligible hospitals, or CAHs to provide any additional information beyond what is generated from certified EHR technology in order to satisfy the requirement for submitting CQM information.
Please note that quality performance results for CQMs are not being assessed at this time under the EHR Incentive Programs. Complete and accurate information for the remaining meaningful use core and menu set measures does not necessarily have to be entered directly from information generated by certified EHR technology. By definition, for each meaningful use objective with a percentage-based measure, certified EHR technology must include the capability to electronically record the numerator and denominator and generate a report including the numerator, denominator, and resulting percentage for these measures. However, with the exception of CQMs, meaningful use measures do not specify that this capability must be used to calculate the numerators and denominators. EPs, eligible hospitals, and CAHs can use a separate, uncertified system to calculate numerators and denominators and to generate reports on all measures of the core and menu set meaningful use objectives except CQMs.
In order to provide complete and accurate information for certain of these measures, they may also have to include information from paper-based patient records or from records maintained in uncertified EHR technology. By agreeing to the above statements, the EP, eligible hospital, or CAH is attesting to providing all of the information necessary from certified EHR technology, uncertified EHR technology, and/or paper-based records in order to render complete and accurate information for all meaningful use core and menu set measures except CQMs.
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