MU2 Progress

tmccormi wrote on Sunday, December 06, 2015:

c1/2/3 are also Harley since Ensoftek dropped it back on us due to resource issues. I can’t reallly afford this effort either, but I can’t afford for it not to be done… sigh

Love to have some one else be a expert at CQM …

bradymiller wrote on Sunday, December 06, 2015:

Hi Tony,
Maybe Visolve can help out since CQM testing looks a bit complicated and they’ve already done it before. What is the financial state of the OpenEMR MU2 funds?
thanks,
-brady

tmccormi wrote on Monday, December 07, 2015:

No change in finances since the last time. All $ have been allocated to the companies that have already contributed to this, though payment is depedent on finishing the Certification. No new money to hire additional help is available, but volunteer labor contributions are alwasys acceptible.

harleytuck wrote on Tuesday, December 08, 2015:

This just in from Milton:
"Please see attached updated project status log.

Please note a testing review has not been completed on any tested requirement and will need to be done prior to certification body submission.

The review will be conducted at the completion of testing.

Regards,
Milton Padilla
[etc]"

Also: I have a8 and b5a scheduled to test Wed; will sched the c1-3 and g2 for as late as possible before the Holidays.

Rgds- HT

bradymiller wrote on Tuesday, December 08, 2015:

Hi Harley,

Thanks for the updated spreadsheet.
I thought item D7(end user device encryption) was already completed? Or should it be a “Need docs” issue instead?

Let me know if you want me to touch base with ZH regarding testing of item f2.

-brady
OpenEMR

tmccormi wrote on Tuesday, December 08, 2015:

D7 passed certification.

harleytuck wrote on Tuesday, December 08, 2015:

Hi Brady-
Yes, please contact ZH about f2. I do not have a high- level fund of knowledge about MU testing requirements; I’ve only focused on the items I’m testing. Which is also why I’m thinking somebody with that high level view should plan to attend the testing review Milton mentioned.
-HT

aethelwulffe wrote on Saturday, December 12, 2015:

Any update on the Wednesday tests?

harleytuck wrote on Saturday, December 12, 2015:

Hi Art-
Yes, they happened. Couple of complications though- Milton elaborated on some of the requirements that might need some more coding. Have passed Milton’s comments to Tony to work his magic on.

E.g., for a8 CDS, must be able to turn on/ off each individual user’s ability to activate specific CDS rules (not just remove Medical/History from that group’s ACL). Also, must show somemessage when a reminder is activated. E.g., popup: “[reminder] has been activated”. Couple others.

b5a Labs seemed to be pretty straightforward; I just had a desktop config thing to straighten out for next testing this coming Wed; should be able to speed through that one.

Here’s hoping the rest of the pieces come together in time!

aethelwulffe wrote on Saturday, December 12, 2015:

Options for a8 CDS:

  1. Complex ACL controls at the per-item basis. This implies those users don’t have access to make ACL changes.
  2. Superuser access to address book or users admin UI that allows flagging of those specified rules as configurable by the user. These flags would be contained in a multi-select field, then parsed for string matches. The actual field would be in one of the user’s tables (users as a single field, or user_settings as different setting_label values.

I can’t think of a way to use the ACL in a simple way to allow dynamic values.
Any other suggestions?
Is anyone assigned to this?
What are the “couple of others” items?

tmccormi wrote on Saturday, December 12, 2015:

I have no “magic” and no idea how to sovle this issue. I assumed that Ensoftek (having passed the certification) had alreay provided that code. but apparently not.

tmccormi wrote on Saturday, December 12, 2015:

I have no “magic” and no idea how to sovle this issue. I assumed that Ensoftek (having passed the certification) had alreay provided that code. but apparently not.

bradymiller wrote on Sunday, December 13, 2015:

Hi Harley and Tony,

Can you list all the specific issues that need to be dealt with for a8(being as specific as possible). Then can address them.

thanks,
-brady
OpenEMR

tmccormi wrote on Sunday, December 13, 2015:

Notable details on a8:

  • need to be able to turn on/ off individual user roles’ ability to trigger individual rules or all the rules
  • when you add an issue to a pt’s problem list it needs to display an active notification that a CDR has been added- having the Clinical Reminder simply appear in the CR widget doesn’t qualify.
  • all the CR’s need to be active links- eg, the ‘Treatment - influenza vaccine’ CR needs to be able to be clicked and then 1) enter the treatment AND if desired, 2) read the reference information about it. At the moment it’s either 1 OR 2: if the CR has a link to information you can’t input results; if it’s set to input results you can’t read the information.
  • needs to be able to import an hl7 format CCD-A containing values in it that trigger the CDS
  • OpenEMR’s CDS needs to be triggered by ordering a med. This is not NewCrop’s drug-drug / drug-allergy reaction checking but OpenEMR’s own CDS system. It’s true that the existing CDS system could accommodate that as a custom rule for each medication being monitored so I guess that’s not exactly a deficiency but I neglected to mention that in the session.
  • CDS needs to have been functioning in a certified fashion for the reporting period this year in order for our customers to be able to attest in 2014. The fact that CDS needs to be re-coded to pass means it has not been functioning in the approved manner this year so nobody can attest with it.

Rgds- Harley

aethelwulffe wrote on Sunday, December 13, 2015:

Ouch. So we are smoke for 2014?
Ouch.
Anywho, I will put together some structure/logic (at least as a point of argument) for the fine user controls.

tmccormi wrote on Sunday, December 13, 2015:

It’s not over til it’s over. Go for it.

fsgl wrote on Sunday, December 13, 2015:

The deadline for 2014 attestation was Feb. 28, 2015. In fact that CMS webpage is no longer available. No reason to dwell on 2014.

The reporting period for 2015 attestation is any continuous 90 days, which means that everything had to be in place by Oct. 1, 2015; consequently 2015 is toast.

CMS Final Rules 10/6/15 (third paragraph from the bottom) provide a 90 day reporting period in 2016 only for first time attesters.

For everyone else it is implied that the reporting period will be 1 entire year. Everything must be done by Dec. 31st of this year; otherwise 2016 will also be toast for repeat attesters.

tmccormi wrote on Sunday, December 13, 2015:

Exaclty what I’ve been saying for the last 6 months. Maybe terror will cause more community devs to help us out here.

Or maybe the basic OpenEMR community is not really interested in MU certification after all and it’s just a problem for the Vendors, which is why ZHH and DrCloudEMR forked the project and did it on their own. Sometimes a single focused and funded team is the only way to hit a goal.

I still prefer the messy open source community model, but it is what it is.

bradymiller wrote on Monday, December 14, 2015:

Hi,

Here are my thoughts on the item a8 issues that Tony brought up above:

OVERALL- I looked at the official testing script on page 14 for these item:

ISSUE #1: need to be able to turn on/ off individual user roles’ ability to trigger individual rules or all the rules

REPLY: Here is the wording of the pertinent testing item 4.03:
Using the Vendor-identified EHR function(s), the Tester shall configure at least
one clinical decision support intervention based on a user’s clinical role that is
inclusive of one of the roles in VE170.314(a)(8) (e.g., triggered for a physician
role but not triggered for nurse or office staff roles)
To support this, would consider the following:

  1. Would echo what Kevin did in the code that assigns document categories to acos:
    Commits · sunsetsystems/openemr · GitHub
    note this code is not completed and not in codebase, but would take same approach:
  2. Add ‘Access Control’ column(to right of ‘Patient Reminder’) to the Administration->Alerts gui which shows the same selector that is shown in Kevin’s code above.
  3. Store this setting in a new sql column called ‘aco_access’ in the clinical_rules table.
  4. Default this new column to ‘patients:med’ (since all rules now are medical, so this will be correct and ensure current rules work correctly)
  5. Make a new rule that is simply checking to see if a Provider is set for a patient, and set the new column in this rule to ‘patients:demo’. A Front Office person will then be able to have this rule processed(after do below).
  6. Then get the CDR engine to work for this mechanism for just the standard rules(don’t touch the CQM or AMC stuff):
    6a. There is a centralized place where it is decided which rules are run(in the library/clinical_rules.php library), so will be easy to select the correct rules there (note that should run all rules if the user has the admin:super aco or if $ignoreAuth = 1).
    6b. Get the active reminder(popup when open the patient chart), passive reminder(Clinical Reminders widget), and patient reminders(Patient Reminders widget) to show up if there are any permitted rules for the user).
    6c. Get the clinical_reminder widget edit->admin to only show the correct rules to activate/deactivate.

ISSUE #2: when you add an issue to a pt’s problem list it needs to display an active notification that a CDR has been added- having the Clinical Reminder simply appear in the CR widget doesn’t qualify.

REPLY: I am unclear what is meant here. Can you provide a specific example?

ISSUE #3: All the CR’s need to be active links- eg, the ‘Treatment - influenza vaccine’ CR needs to be able to be clicked and then 1) enter the treatment AND if desired, 2) read the reference information about it. At the moment it’s either 1 OR 2: if the CR has a link to information you can’t input results; if it’s set to input results you can’t read the information.

REPLY: This issue partially makes sense; the part that makes sense can simply use a popup tip(like is done in the encounter listing screen that shows notes when hover them) when hover over the items with no link(that displays the reference information)(this would just require some simple modifications to the function in library/clinical_rules.php that builds the Clinical Reminders widget). The part that doesn’t make sense is there is no place in the testing script that states the notification needs to link the user to the place to enter in the data(ie. the reminder that tells the user to get a smoking history does not need to provide a link to the history input form).

ISSUE #4: Needs to be able to import an hl7 format CCD-A containing values in it that trigger the CDS

REPLY: This will already happen if import a CCDA via ZH’s Care Coordination module. If need instructions to do this, rec touching base with ZH.

ISSUE #5: OpenEMR’s CDS needs to be triggered by ordering a med. This is not NewCrop’s drug-drug / drug-allergy reaction checking but OpenEMR’s own CDS system. It’s true that the existing CDS system could accommodate that as a custom rule for each medication being monitored so I guess that’s not exactly a deficiency but I neglected to mention that in the session.

REPLY: This is already supported and there is already even a active rule for this: type in Coumadin for a medication, and then a INR lab check reminder will show up.

-brady
OpenEMR

aethelwulffe wrote on Monday, December 14, 2015:

OooooKaaaay…That is a bit different for Item #1. Any time we are assigning user roles on a per-user basis, a heavy multi-select input is a need. Too much testing happens with only 2 or three providers/users in the database. I didn’t get very far parsing Kevin’s code…I’ll try again when awake.

So, no money for 2015 (meaning the 2014 requirements…not actually FOR 2014) for us if we can’t attest for the last quarter. Sad, because if a few people here had gotten off their ass we could have had every dime up til now…including this year is we had gotten it done by September (MU1 for Florida Medicaid). Oh well. I have never had an IT budget before, and we have been plugging away for 8 years now. Guess it’s time to head to recycling at the land fill and dredge up some more parts for the server. :frowning: