a. All providers are now in Stage 2 of Meaningful Use — with a “Modified Stage 2” for providers that were previously in Stage 1.
b. The core and menu measures have been simplified into 10 “Objectives.”
c. Record Demographics, Record Vital Signs, Record Smoking Status, Clinical Summaries, Structured Lab Results, Patient List, Patient Reminders, Summary of Care Measure 1 – Any Method and Measure 3 – Test, Electronic Notes, Imaging Results, and Family Health History have been removed from the REPORTING requirements
d. The Stage 2 measures that required patient engagement have been greatly reduced. The threshold for the measure Patient Electronic Access: View Download and Transmit health information dropped from 5% to “at least one patient seen by the EP during the reporting period.”
As things stand now when one visits the Certified Health IT Product List website at http://oncchpl.force.com/ehrcert and selects openEMR 4.2 we get: STATUS : Base Criteria 23%, CQM Domains 0%, Inpatient CQMs 0%, Ambulatory CQMs 0%. The ‘Get Certification ID button’ will not become active till 100% is reached for Base Criteria, CQM Domains and Ambulatory CQMs.
I am also aware that OEMR.org is in the process of getting certification for Meaningful Use Stage 2.
My question is in 4 parts
Will the re-certified community version of openEMR 4.2 with e-Rx and phiMail add-ons be able to get a CMS EHR Certification ID Number?
What additional modules, if any, will be needed to get the certification number?
What is the time frame for the certification process?
How will one go about reporting Meaningful use modified stage 2 requirements?
First time attesters for 2016 will need to become acquainted with this guide. One cannot attest to MU2 without attesting to MU1.
It is not possible to obtain a Certification ID until OpenEMR is fully certified with the 2014 Edition. A user cannot use OE until all the code changes are in the codebase. To follow the progress, use the Completion Barometer.
Hopefully 2014 Edition CEHRT will be achieved within the first 2 quarters of 2016. If certification is not achieved by September 30, 2016; the first time attester may be required to obtain a Hardship Exception by July 1, 2016.
If the attester is fresh out of postgraduate training, the exception is granted automatically without applying for it.
Note that the program has progressed from the “carrot” phase to the “stick” phase, hence the exception application may be necessary to forestall Medicare penalties.
After full certification there will be a guide in Supplementary, under the Meaningful Use subsection, covering 2014 Edition attestation.
The time frame for the Medicaid program is more elongated compared to the federal program, but the attestation requirements are essentially the same.
I don’t think that there are any penalties in the Medicaid program. It is unclear how participation in the state programs affect Medicare reimbursements. I would surmise that successful attestation via Medicaid would also satisfy Medicare.
It is certain that non-participation in either program & in the absence of an exception will incur Medicare penalties.
There does not appear to be any elimination of Stage 1 for first time attesters for the 90 reporting period in 2016.
Although both stages have 10 objectives in addition to the 9 CQM’s, the requirements within an objective may differ for the first time attester and the returning attester.
A good illustration of the differences between the 2 stages in the Modified Requirements is CPOE on page 1. The first time attester has a lighter burden in that he has a 30% threshold, not 60% for the Stage 2 attester, regarding meds.
The Stage 1 attester does not have the requirements for labs & imaging if he claims the respective exclusions; while returning attester must report on all 3, because the alternate exclusions are not available to him.
2011 Edition had only Stage 1. 2014 Edition has Stage 1 & Stage 2. In all likelihood 2015 Edition will have Stages 1, 2, & 3.
Shortly after OpenEMR has been certified for the 2014 Edition, the Wiki will be updated with a new attestation article.
The Completion Barometer tracks progress on 2014 Edition CEHRT. Planning on the 2015 Edition certification has not yet begun, therefore work is far off in the future.
Thank you for the info about the meaningful use criteria for 2015-2017. After reading that document it appears that a first time attestor in 2015 needs to attest to the following:
Objective 1Protect Patient Health Information
Objective 2Clinical decision Support Implement one clinical decision support rule
Objective 3 Computerized Provider Order Entry 30% of all unique pts with at least one medication order with CPOE or more than 30 percent of medication orders created by the EP using CPOE.
Objective 4: Electronic Prescribing More than 40 percent of all permissible prescriptions written by the EP are transmitted electronically using CEHRT
It appears that one is allowed to take an exclusion for Objectives 5, 6, 7, 8 and 9.
The basis of exclusion for objectives 5, 8 and 9 is it does not have an equivalent measure in Meaningful use Stage 1. The language for the basis of exclusion for objectives 6 and 7 is a bit confusing - they were
scheduled to demonstrate Stage 1 but did not intend to select the Stage 1 Patient Specific Education menu objective or did not intend to select the Stage 1 Medication Reconciliation menu objective.
Yes, first time attesters need to report on only 5 objectives if the appropriate exclusions are claimed.
ONC-HIT should have titled the changes as Modified 2014 Edition, not Modified Stage 2, which is major source of befuddlement.
CMS also has a bad habit of changing things after having “finalized” a rule. They did the same thing in 2014. It’s final until they decide to change it again.
The modified requirements took effect on 10/6/15. If you have the stamina to look it up in the Federal Register, my hat off to you. The Federal Register is usually clear as mud. It maybe be easier to wait for CMS to flesh out the 2016 requirements webpage.
Thank you once again for going patiently through this issue. Alas I realize that while the reporting requirements for first time users for 2015 are not too onerous the certifying requirements for openEMR 4.2 are many. I sincerely hope that timely certification will become a reality.
If and when certification is achieved I am curious to know how this data will be retrieved from the application.
Another interesting point is that so far the modular certification for 2014 is approved for only 8 criteria:
170.314(a)(13) FAMILY HEALTH HISTORY
170.314(d)(1) AUTHENTICATION, ACCESS CONTROL, AND AUTHORIZATION
170.314(d)(4) AMENDMENTS
170.314(d)(5) AUTOMATIC LOG-OFF
170.314(d)(6) EMERGENCY ACCESS
170.314(d)(9) ACCOUNTING OF DISCLOSURES (OPTIONAL)
170.314(f)(1) IMMUNIZATION INFORMATION
170.314(g)(4) QUALITY MANAGEMENT SYSTEM
How did anyone get a CMS EHR Certification ID Number using the community edition?
How did they attest to meaningful use in 2014?
What additional modules were needed for meaningful use attestation in 2014?
More often than not, it is a learning experience for myself as well, when visiting the CMS website; because they’ve changed things yet again.
Have a look at this attestation guide. Perhaps it will satisfy some of the curiosity about the nuts & bolts of attestation. An analogous Wiki article will be written for the 2014 Edition.
You are correct that attestation requirements pale in comparison to certification criteria. Specifically the criteria for electronic reporting of Clinical Quality Measures drove the developers crazy.
The Completion Barometer is a more accurate record of work accomplished. Unfinished is g2; while a8, b5, c1, c2, c3, f2, g1 need testing with Infogard.
In August 2014 CMS promulgated the Flexibility Rule, whereby attesters could use either the 2011 or the 2014 Edition. Those of us who attested, used the old Certification ID from the prior years for the 2011 Edition.