MU2 Final Rule

tmirc wrote on Tuesday, January 13, 2015:

on CMS site it says for 2014 we can use Stage 1 criteria to attest, but it says:

Providers scheduled to demonstrate Stage 1 in 2014 who have successfully implemented 2014 CEHRT would use 2014 Stage 1 core and menu objectives.

Providers who are still using 2011 Edition CEHRT or a combination of 2011 and 2014 Editions and choose to report 2013 Stage 1 core and menu objectives should visit the 2013 Stage 1 of Meaningful Use webpage .

can some one explain what criteria should we be using for 2014, we originally attested

Ist attestation - 2012 (stage 1)
2ed attestation - 2013 (stage 1)

3rd attestation - 2014 - what core and menu objectives should we be using ?

should openemr 2011 Edition CEHRT is sufficient to attest or do we need combination of 2011 and 2014 Editions? which means do we need to upgrade to 4.2.0 before attesting?

fsgl wrote on Tuesday, January 13, 2015:

Use only 2011 CEHRT for your third attestation for 2014.

4.2.0 has not been certified for 2014 CEHRT yet.

There is no other choice except to use 2011 CEHRT.

Deadline is February 28, 2015.

tmirc wrote on Tuesday, January 13, 2015:

Thank you

fsgl wrote on Tuesday, January 13, 2015:

It was my pleasure.

The attestation police knocked on the doors of at least 2 Forum members. They’re doing pre-payment & post-payment audits.

If you’ve not seen this; take it to heart & document, document, document.

Best of luck with the attestation.

umasc wrote on Tuesday, January 20, 2015:

We are planning to register for MU Stage 1 this year. So far we were using openemr 4.1.0. Can we move to 4.1.2-7 to provide 90-day data for MU stage 1 this year?

visolveemr wrote on Wednesday, January 21, 2015:

Hi Uma,

Is the data already collected in year 2014 or you are going to start the reporting period in 2015?

If you have collected data in 2014, then you can go with Openemr 4.1.0 since it is the version certified under 2011 edition.

If you are going to start in current year, then you need to use 2014 edition certified ehr for reporting. Refer the link given HERE.

Thanks
OpenEMR Customization/Support Team,
ViSolve Inc
services@visolve.com
Demo’s @ ViSolve Demo Library

bradymiller wrote on Wednesday, January 21, 2015:

Hi,

To clarify.

All 4.1.x versions have Complete certification for 2011 MU1.
http://www.open-emr.org/wiki/index.php/OpenEMR_Wiki_Home_Page#2011_ONC_Ambulatory_EHR_Certification

And all 4.2.x versions have and will have Modular certification for 2014 MU1/MU2.
http://www.open-emr.org/wiki/index.php/OpenEMR_Wiki_Home_Page#2014_ONC_Ambulatory_EHR_Certification

(and in the future, will plan all 4.3.x versions to have Complete certificaton for 2014 MU1/MU2)

As an aside, for users that want 4.2.x functionality but need MU1 certification, I did create a 4.1.3 branch that is essentially 4.2.0 just in case users needed this(before doing this, though, should check in with Tony at OEMR to ensure doing that is ok):
https://sourceforge.net/p/openemr/discussion/202506/thread/4645a14f#9f1c

-brady
OpenEMR

yehster wrote on Wednesday, January 21, 2015:

From ViSolve’s link.

All eligible professionals, eligible hospitals, and CAHs are required to use the 2014 Edition CEHRT in 2015.

So 4.1.x is not sufficient in 2015, as it is does not have a 2014 certification.

yehster wrote on Wednesday, January 21, 2015:

So 4.1.x is not sufficient in 2015, as it is does not have a 2014 certification.

fsgl wrote on Wednesday, January 21, 2015:

Would suggest the following because time is rapidly drawing down:

  1. Use 4.1.0 for the attestation. Patch later.
  2. Use this guide. It has instructions for registration.
  3. Pick any quarter (not any 90 days) for the reporting period wherein all your data is air tight & for which you have solid documentation.

38 days is not a lot of time to register and attest, but it can be done with excellent preparation.

tmccormi wrote on Wednesday, January 21, 2015:

By the book, any release 4.1.X is good for MU stage 1. There are stage 2
related changes in the 4.1.3 release so if you are squeamish about that
stick with 4.1.2 for Stage 1.

Tony


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yehster wrote on Wednesday, January 21, 2015:

4.1.x does NOT have a 2014 certification, which seems to contradict your statements, based on this statement from CMS.

All eligible professionals, eligible hospitals, and CAHs are required to use the 2014 Edition CEHRT in 2015.

tmccormi wrote on Wednesday, January 21, 2015:

I said it was for Stage 1 (2011) is what I meant by that.

Tony McCormick, CTO

tmccormi wrote on Wednesday, January 21, 2015:

There is this … that can help while we continue to make progress on MU 2 2014

tmccormi wrote on Wednesday, January 21, 2015:

This is relevant information and, really, up holds Kevin’s statement. You will need to upgrade to 4.2 (and 4.3) in order to do 2014 attestation whether Stage 1 or Stage 2 criteria are used. Fortunately, it looks like the same 90 period applies for previous attestations (at least).

fsgl wrote on Thursday, January 22, 2015:

Just checked the Certified Health IT Product List. See attachment.

Although the CMS EHR Certification Number can now be obtained for 4.2.0, it cannot be used for 2014 certification.

The deadline for the release was September 30, 2014 in order for the user to have the last quarter of 2014 for the reporting period.

Given the contradictory attitude of Congress about taxpayer dollars being misspent by CMS in the way it has had administered MU, I would hesitate to attest using Modular Certification; instead it would be safer to rely on the version of OpenEMR that has Complete Certification.

It was in response to Congress’ mixed message that Figliozzi & Co. began auditing physicians & hospitals in April 2012.

umasc wrote on Thursday, January 22, 2015:

Thanks all for your input.

“OpenEMR 4.2.0 is going to be released before 1/1/15 and it will have 2014 EHR Modular Certification(note OpenEMR will NOT have full 2014 certification by this time).” from http://sourceforge.net/p/openemr/discussion/202506/thread/4645a14f#9f1c

Does this mean 4.2.0 will have 2014 EHR modular certification for MU2? If so, does that also mean 4.2.0 will have 2014 complete certification for MU1? Which openemr version has 2014 complete EHR certification for MU1?

bradymiller wrote on Thursday, January 22, 2015:

The Flex-IT act (would allow 90 day attestation for year 2015) is still not official:
http://www.medicalpracticeinsider.com/news/flex-it-act-gathers-support

bradymiller wrote on Thursday, January 22, 2015:

Hi,
I edited my post above to clarify the 2011/2014, so :
All 4.1.x versions have Complete certification for 2011 MU1

All 4.2.x versions have and will have Modular certification for 2014 MU1/MU2.
-Note that 4.2.0 was released on 12/24/2014

All 4.3.x versions will have Complete certification for 2014 MU1/MU2.
-Note OpenEMR is still working on getting Complete certification, but when OpenEMR has it, then version 4.3.0 will be released:
http://www.open-emr.org/wiki/index.php/OpenEMR_Certification_Stage_II_Meaningful_Use#Completion_Barometer

hope that clarifies things for you,
-brady
OpenEMR

sunsetsystems wrote on Wednesday, February 04, 2015:

Brady said:

The Flex-IT act (would allow 90 day attestation for year 2015) is still not official:
http://www.medicalpracticeinsider.com/news/flex-it-act-gathers-support

Can someone tell me where this stands?