Your Certified EHR will do everything you need, right? And if it does not, it is the vendor’s issue, right?
Here’s an interesting extract from the criterion by which EHR software is certified for the process of Automated measure calculation (170.302 (n)). The regulations state that this criterion requires
“For each meaningful use objective with a percentage-based measure, electronically record the numerator and denominator and generate a report including the numerator, denominator, and resulting percentage associated with each applicable meaningful use measure.”
Clear enough. But look at the detail instructions for actually validating that this occurs, and you may be surprised by the minimum requirement:
The Vendor provides the test data for this test procedure.
This test procedure is organized into two sections:
– Record – evaluates the capability to electronically record the numerator and denominator for each meaning use objective with a percentage-based measure
o If the Vendor indicates that the EHR automatically records the numerator and denominator
for the measure, the Tester proceeds to the Generate Report step below.
o If the Vendor indicates that the EHR does not automatically record the numerator and/or
denominator, the Tester uses Vendor-identified functions and Vendor-supplied
numerator/denominator values to enter numerator/denominator information into the EHR.
– Generate Report – evaluates the capability to generate a report that includes the numerator,
denominator, and resulting percentage associated with each percentage-based meaningful use
o The Tester generates a report that includes the numerator, denominator, and resulting
percentage associated with each percentage-based meaningful use measure
o The Tester validates that the report is generated and is accurate and complete based on
Ok let’s read between the lines here. First, the vendor is only required to calcualte and display the numerator, denominator and any associated percentage. They are not required to provide any detail reporting to support or prove this percentage. Prudent vendors probably will but certification is not a guarantee.
Secondly, if the vendor’s software does not automatically calcualte the numerator and denominator, they can still pass the test! All they need do, is have the ability to enter the numerator and denominator into their system, and from there calculate a percentage.
We derive two action items from this set of observations.
1. Quickly figure out how your vendor’s software works
2. Quickly find the reporting in your vendor’s software that shows the details associated with each measure. If the report does not exist (and it is not required to exist), they you might want to get your Business Intelligence Team on it.