Guidelines for Attestation with Multiple EHR Technologies

We were chatting recently with a tester from one of the  ATCB’s who issue EHR software certifications on behalf of CMS.  As you know, the first step towards compliance with the ARRA laws enabling hospitals to receive EHR stimulus funds is in actually owning certified EHR software.  Our friend there has been involved in testing EHR’s for the purpose of “self-certification”.  Self certification becomes a necessity more often than you might imagine … but that’s a topic for a different day.

At this particular ATCB, we heard that a majority of the hospitals presenting themselves for self certification were doing based on a combination of multiple EHR technologies.  What an intriguing set of pragmatic issues this raises!  Let’s explore a few, with some ideas on solutions.

  1. Roll up of Measures – You’ll need some way in which to aggregate numerator, denominator and the resulting percentage across multiple EHR’s, when it comes time to attest.
  2. Aggregation of “Audit Proof” – as we’ve discussed elsewhere, attestation is probably a lot easier than providing detail documentation acceptable to a skeptical CMS auditor, who can show up on your doorstep for up to 6 years after attestation.  Depending on CMS’ perception of program performance, these auditors may be inclined to merely check that your technology can calculate a percentage – or may be inclined to evaluate detailed lists of unique patients under the circumstances of each unique MU measure.   Risk-adverse organizations will probably create reporting across multiple EHR’s to pull the requisite details, with a track-back to the specific EHR in which patients are maintained.
  3. Yes/No Attestations – Counting Core and Menu items, there are 9 measures for which you can attest by merely saying “yes” or “no”.  The conservative approach is to make sure that for each of these measures, you should be prepared to defend a “yes” attestation across all EHR’s in your inventory.
  4. Denominator for Measures that count “All Patients Maintained in Certified EHR technology”– similar to Yes/No attestations, it seems prudent (under a conservative approach) to account for all unique patients across all EHR’s rather than just a single core product.
  5. Denominator for Measures that count “All patients“, regardless of whether they are maintained in Certified EHR – Patients in your OB ward whose records never make it to the core inpatient EHR system probably are one example – particularly if they are maintained in a standalone EHR that has not been certified.  When calculating this type of measure, and there are several, make sure you isloate these “non-certified EHR” patients and count them appropriately, as you conduct your measure rollups for hospital-wide attestation and audit proof.
  6. EHR Certification Number – This one stumped me at first, but there is a simple answer.  When a provider signs up to attest to Meaningful Use, the attestation site asks if you have a certified EHR.  And it provides a field in which you report yours.  But there is only one field!  Here’s how it works.  On the Certified EHR Product List (CHPL) website at … Select the first EHR in your inventory, and add it to your shopping cart.  Find each of the other certified products, and add them as well. When you check out, CMS will aggregate these products together and give you a single, aggregated certification number usable in your Attestation.  If you’ve self certified one or more products, they will be on the CHPL site as well, and will simply be one of the selections you make.

I’ll bet there are other practicalites we’ve not investigated here.  Share your thoughts, and between us, we’ll come up with a comprehensive point of view!

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