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Washington Debrief: CMS Clarifies CEHRT Requirements for 365-Day Reporting

October 6, 2014
by Jeff Smith, Vice President of Public Policy at CHIME
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Jeff Smith, Vice President of Public Policy at CHIME

Top News

CMS Clarifies CEHRT Question: What has to be in place for full 365?

Key Takeaway: The Centers for Medicare and Medicaid Services (CMS) published clarifications last week describing what pieces of 2014 Certified Electronic Health Record Technology (CEHRT) need to be in place for the full 365 days, vs. what functionalities can come online at some point later in the 2015 reporting period.

  • Hospitals must have clinical decision support, including drug-drug and drug-allergy checks in place “Day 1,” or otherwise the entire 2015 program year is lost.
  • Hospitals must also have successful ongoing submission of all public health measures in place by the end of November, or risk failing meaningful use in 2015.
  • For all other measures of MU, hospitals must meet thresholds, but do not have to be live with modules, according to current policy.

Why It Matters: These new clarifications will benefit providers who did not have all modules of 2014 Edition CEHRT in place beginning Oct. 1, 2014. However, many healthcare IT leaders continue to voice their support for a policy change that would shorten the 2015 reporting from a full year to 90 days.

Next Steps: CHIME staff in Washington is continuing to utilize their direct line of communication with officials at ONC and CMS to help them recognize the situation "on the ground."

CMS issued an important clarification regarding what modules need to be in place for program year 2015 in a statement sent through their listserv last week. According to the announcement, if you are attesting to Stage 1 in program year 2015, you must have the Drug-Drug / Drug-Allergy Interaction Checks piece in place for the full 365-day reporting period. If you are attesting to Stage 2 in program year 2015, you must have clinical decision support for Drug-Drug / Drug-Allergy in place beginning last Wednesday, Oct. 1. If these pieces were not in place, you have failed Meaningful Use in 2015.

Some public health objectives have 60 days to allow for registration and test submissions. Some states have different rules and may require retroactive submissions, so please check with your state. Public health flexibilities exist for:

  1. Stage 1 and Stage 2 Immunization Registries Data Submission
  2. Stage 1 and Stage 2 Electronic Reportable Lab Results
  3. Stage 1 and Stage 2 Syndromic Surveillance Data Submission

In summary, eligible providers (EPs) and eligible hospitals (EHs) aren’t necessarily required to have all functionalities in place on the first day of the 365-day reporting period; as long as they meet the threshold for objectives with a numerator and denominator during the year, they satisfy the requirement.

If you would like to read more about the requirements, check out these helpful specifications sheets: Stage 1 and Stage 2, and visit the EHR website for more resources.

Legislation & Politics

CMS Registration and Attestation Website Failures Addressed in 2nd Congressional Letter

Key Takeaway: This week, the CMS’s meaningful use Registration and Attestation website came under fire once again from Capitol Hill, this time from the Senate. Senator Kay Hagan (D- N.C.) requested CMS not assess penalties next year on providers who attempted to attest to meaningful use with 2011 CEHRT but were rejected because the website lacked proper configuration.

Why it Matters: The inability of the website to accept attestation data may be directly impacting thousands of physicians who had until Oct. 1, 2014 to attest to their first year of Meaningful Use or face penalties in 2015. The CMS attestation website has sometimes been a subject of concern for providers that faced similar glitches last year. When approached about this issue, CMS officials noted that these EPs had an opportunity to file a hardship exception by July 1 and should have done so.