Clinical Quality Measures

InfoGard Accredited to Test Clinical Quality Measures

On August 22, 2016, InfoGard achieved accreditation from NVLAP (Lab Code 100432-0) to begin testing to the 2015 Edition certification criteria for Clinical Quality Measures (CQMs). The CQM criteria include:

  • 315(c)(1) – Clinical quality measures –record and export
  • 315(c)(2) – Clinical quality measures –import and calculate
  • 315(c)(3) – Clinical quality measures—report
  • 315(c)(4) – Clinical quality measures –filter

The measures tested under the 315.c.1-4 criteria are used by providers and hospitals for the CMS Meaningful Use Program in 2017 and beyond.

The test procedures can be found on the ONC website: https://www.healthit.gov/policy-researchers-implementers/2015-edition-test-method

The test tool, Cypress, can be found at: http://projectcypress.org/index.html

CMS information about the CQMs is available: https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/eCQM_Library.html

InfoGard understands that developers may have delayed testing until these criteria were available. Don’t delay any longer! Contact us to get started today!

Meaningful Use

Meaningful Use Update

In 2015 CMS released the Final Rule that outlines the requirements eligible professionals (EPs) and eligible hospitals (EHs) must fulfill in order to participate in the Medicare and Medicaid EHR Incentive Programs, also known as Meaningful Use. The Final Rule addresses participation in 2015 through 2017 with changes to Stage 2, as well as establishing Stage 3 in 2018 and beyond.

Stages for Meaningful Use and Objectives

Stage 1 – 2011 to 2013 – Data capture and sharing

Stage 2 – 2014 to 2017 – Advanced clinical processes

Stage 3 – 2018 to TBD – Improved outcomes

The CMS Rule allows providers to start Stage 3 of Meaningful Use in 2018, with 2017 as an optional year for Stage 3 participation.

Reporting Periods to Qualify for MU

The reporting periods for EPs and EHs are aligned beginning in 2017 to run on the calendar year. In terms of objectives, the Rule set out eight (8) objectives that providers are required to meet, while establishing a single set of objectives and measures, tailored to EPs, EHs, or critical access hospitals (CAHs), to meet for the definition of Meaningful Use.

In 2016 (Stage 2) – First-time participants may use their EHR to report through any continuous 90-day period between January 1 and December 31, 2016.

All returning participants must use their EHR to report the full calendar year (January 1-December 31, 2016).

In 2017 (Stage 2 or Stage 3) – First-time participants may use their EHR to report through any continuous 90-day period. Providers attesting to Stage 3 may also use a 90-day reporting period. All returning participants must use their EHR to report the full calendar year (January 1-December 31, 2017).

In 2018 (Stage 3) – First-time Medicaid participants may use their EHR to report through any continuous 90-day period. All other providers must use a reporting period of the full calendar year (January 1-December 31, 2018).

For more information, visit the CMS EHR Incentive Program, https://www.cms.gov/regulations-and-guidance/legislation/ehrincentiveprograms/.

2015 Edition and MU Stage 3 Final Rules Published

This week ONC published the Final Rule defining the 2015 Edition of EHR certification requirements. In addition, CMS released the Final Rule for Meaningful Use Stage 3.

2015 Edition: https://www.healthit.gov/policy-researchers-implementers/2015-edition-final-rule

Stage 3: https://s3.amazonaws.com/public-inspection.federalregister.gov/2015-25595.pdf

What this means for EHR developers:

The 2015 Edition certification criteria are the next set of criteria used to certify EHRs. Vendors will need to use these criteria when developing their products to be used for Meaningful Use. Testing to the 2015 Edition is expected to start in early 2016.

What this means for providers/hospitals:

According to the rule from CMS, Stage 3 will start in 2018 with an optional year starting in 2017. This gives providers and hospitals 2 years (2016-2017) to select and install an EHR certified to the 2015 Edition certification criteria.

More information on the ONC Health IT Certification Program can be found at: https://www.healthit.gov/policy-researchers-implementers/onc-health-it-certification-program

More information on Meaningful Use can be found on the CMS EHR Incentive Programs website at: http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/index.html.

See also the press release by HHS: http://www.hhs.gov/news/press/2015pres/10/20151006a.html

2015 Edition Proposed Rule – Proposed Gap Certification Criteria

In the 2015 Edition Proposed Rule ONC lists the criteria that are proposed to be eligible for Gap Certification. If you want to get a jump on the 2015 Edition, have your Health IT Module (formerly called EHR Module or Complete EHR) certified to some or all of the 2014 Edition criteria. You should then be able to focus your efforts on developing to the new 2015 Edition criteria and utilize the Gap Certification option for the below criteria. The 2015 Edition Proposed Rule identifies 20 criteria that will be eligible for Gap compared to only 12 criteria that were eligible from the 2011 Edition to the 2014 Edition. Continue reading

2015 Edition Proposed Rule – Change Reporting for Certified EHRs

In the 2015 Edition Proposed Rule, ONC has put forth a recommendation that would require ONC-ACBs to obtain monthly reports from developers of certified EHR products of any adaptations or updates made to their certified EHRs. These reports would provide awareness to ONC-ACBs of changes and adaptations that could in turn feed into decisions of when to conduct surveillance on a specific EHR (see blog post from May 4, 2015). Continue reading

2015 Edition Proposed Rule – ONC’s Proposed Surveillance Requirements, “In-the-field”

In the 2015 Edition Proposed Rule, ONC proposes to require in-the-field surveillance to be conducted by ONC-ACBs. The concept of in-the-field surveillance has been included in previous Rules, but here ONC provides further guidance on when it must be utilized.

In the Proposed Rule, “in-the-field” is defined as, “an ONC-ACB’s assessment of whether a certified Complete EHR or certified Health IT Module to which it has issued a certification continues to conform to the certification’s requirements once implemented and in use in-the-field.” ONC goes on to clarify that this would require the ONC-ACB to perform the assessment utilizing PHI (or equivalent test data) at a user site. Continue reading

Health IT Module

2015 Edition Proposed Rule – Changing “EHR Module” to “Health IT Module”

In the 2015 Edition Proposed Rule, ONC has recommended that the term “EHR Module” be changed to “Health IT Module”. This change would support the expansion of the ONC Health IT Certification Program to include other types of Health IT besides just EHRs.

ONC has already removed the term “Complete EHR” for any edition after the 2014 Edition (see the 2014 Edition Release 2 Final Rule). The change to Health IT Module would remove the term “EHR” from the Certification Program entirely. Continue reading

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ONC 2015 Edition Criteria and MU Stage 3 Proposed Rules Announced

ONC has published a proposed rule defining the 2015 Edition of EHR certification requirements.

An email announcement from ONC on March 20, 2015 revealed the following information:

“The 2015 Edition Health IT Certification Criteria proposed rule aligns with the path toward interoperability – the secure, efficient, and effective sharing and use of health information…” Continue reading

Certification Criteria

Removal of the 2011 Edition Certification Criteria

In the Final Rule for the 2014 Edition Release 2 Certification Criteria (published in Sept. 2014), ONC removed the 2011 Edition Certification Criteria from the Code of Federal Regulations (see Section C on Page 54447). As of March 1, 2015, the certification criteria 170.302, 170.304, and 170.306 can no longer be tested and certified by the Accredited Testing Laboratories (ATL) and Authorized Certification Bodies (ACBs). Continue reading