I think I may be a little behind the ball here, but I just found out that if our practice can't "fully Implement CPS12" we can use CPS 10 (2011 technology) to attest for MU stage 2. I read on the federal Register that we have a couple options, but im still a little confused. We are still in the testing phase of CPS 12, and I am pushing so hard to full implementation by Oct 1.
1-Push ahead and Attest to MU stage 2 with 2014 technology
2-use 2011 technology (for me would be CPS10) and attest to basiclly Stage 1 year 3. then in 2015, we would have to be using 2014 technology.
3 - Use a combination of both systems. (this won't happen, it will have to be either one system or the other)
Is anyone else totally confused as to what to do? and When the final rule will come out?
I am trying to find a link to one specific story - about an announcement by CMS of waiver/delay - to be made on or about Sept 1, 2014. However, I did find these couple of links to some background on the matter:
http://www.ihealthbeat.org/art.....ul-use-pay
http://www.ihealthbeat.org/art.....se-in-july
So, many are waiting to learn about the announcement - yes, September 1 is a holiday - to understand if CMS believes it a hardship and not possible for health care providers to attest given delays by software vendors and needed times to modify and implement changed workflows.
Two recommendations when upgrading to CPS12...
1. Get up to SP4 if at all possible. There are some major crashes in SP3 and lower, and our providers typically hit them several times a day.
2. Ask your GE tech about the SP4 bug in the stored procedure mikCreatePatientVisit. Refer to SR 1-512953454. Having the fix ready in advance will save you possibly days of not being able to import charges, especially if you're upgrading over a weekend when there's nobody available at GE who is qualified to help you.
Monsterglue,
According to the decision tool (see link below) published by CMS it looks like you can go with your option #2. It seems anyone that has has not upgraded to CPS12 may attest to Stage 1 measures.
In fact, even if you did upgrade to CPS12 you may attest to Stage 1 if you chose.
http://www.cms.gov/Regulations.....onTool.pdf
Is that how everyone else interprets this?
Mike
I read it the same way, even if you have fully 2014 certfied system and you are due for stage 2, you can still attest 2014 stage 1, which will be a lot easier to configure and ensure we are meeting all of the requirements on time
If you are on CPS 12, how are you going to get reports since we still do not have our CQR's? The crystal reports in CPS 12 don't work do they?
I figured GE's CQM tool probably didn't work right still, so i think my practices are going to stay on CPS 10 until Jan 1. Then attest to Stage 1, and move on. Does anyone know if we have to have special documentation to attest to Stage 1. I mean how do we prove that we arn't upgrading? Do we need something from GE? Ive been auditied 2 times in 2 years, so im always looking to have the right documentation.
Right? The Final Rule says that they'll make sure to tell the auditors what documentation you need, but doesn't mention anything about what documentation that might possibly be. I'm wrestling with our VAR a bit in getting something in writing.
My point to them is, nothing happens to them if they give me documentation that things are wonky and I don't need it. But if they don't give it to me and I DO need it, I'm the one that's screwed, not them. Normally I love them, but I think they're worried about getting smacked down by GE. :/
Same boat here, Audited 2 times in two years. We need that documentation too and use a VAR (not GE).
This waiting in limbo finding out wen CQR will work or "if" it works in CPS 12 is horrible......
Dear Customers,
GE Healthcare has released the following information regarding the
updated 2014 Meaningful Use attestation flexibility final rule.
We highly recommend you join the webinar scheduled for tomorrow,
September 5th at 10:00AM PDT.
Message from Peter Kinhan:
On August 29, the Center for Medicare and Medicaid Services (CMS)
and the Office of the National Coordinator for Health Information Technology
(ONC) issued a final rule on
flexibility for attestation for Meaningful Use in 2014. As expected, the
rule eased requirements for attesting to Meaningful Use in 2014. To be
eligible, providers must attest that they could not fully implement 2014
Edition Certified Health Record Technology (CEHRT) to meet Meaningful Use for
an EHR reporting period in 2014 due to delays in 2014 Edition CEHRT
availability. The Final Rule left unchanged the requirement to use 2014 CEHRT
for the full reporting year in 2015.
The rule allows Eligible Professionals (EPs) who can attest to being eligible
for the options established in the Final Rule to now meet Meaningful Use this
year using one of the following technology options: 2011 CEHRT, a mix of
2011 and 2014 CEHRT, or 2014 CEHRT. In addition, these eligible EPs can attest
this year by meeting the 2013 or 2014 Stage 1 measures using these CEHRT
options, even if scheduled to begin Stage 2 this year.
CMS has provided resources to help you identify your options for 2014
attestation, and they can be found at the links below:
- CEHRT Interactive Decision
Tool - providers answer a few questions about their stage of
Meaningful Use and Edition of EHR certification, and the tool displays the
corresponding 2014 options. - 2014 CEHRT Flexibility
Chart - a visual overview of CEHRT participation options for 2014. - 2014 CEHRT Rule Quick Guide
- provides corresponding resources based on the option a provider
chooses to participate in the EHR Incentive Programs in 2014.
GE customers will likely follow one of three key scenarios to
attest. The rules can be complex, so we are conducting a comprehensive webinar
this Friday, September 5, to help you understand your options.
Scenario 1: Have not upgraded
Criteria:
- Currently using Centricity™
Practice Solution (CPS) 9.5, 10.x, 11.x or Centricity EMR (CEMR) 9.5
-AND- - Customers can attest to eligibility
for one of the Final Rule options
Typical Guidance: Customers in this group will most likely
generate reports using 2011 certified technology against the 2013 Stage 1
criteria and then complete their upgrade prior to January 1.
Scenario 2: Upgrade is incomplete
Criteria:
- Currently using CPS 12 or CEMR 9.8
but have not "fully implemented" all 2014 technology and are
able to attest to eligibility for one of the Final Rule options.
Example of "fully implemented" includes adjustments to workflows,
training, etc. -OR- - Upgraded in the middle of a
reporting period
Typical Guidance: Customers in this group will most likely
generate reports retrospectively using 2011 certified technology against the
2013 Stage 1 criteria and then complete their upgrade prior to January 1.
During a webinar on September 5th, we will review additional options for
customers who plan to use a combination of 2011 and 2014 CEHRT during the
reporting period.
Scenario 3: Have "fully implemented" 2014 CEHRT
Criteria:
- Currently using CPS 12 or CEMR 9.8,
-AND- - Have "fully implemented"
all 2014 technology to support Meaningful Use attestation for 2014
measures for a complete reporting period. Example of "fully
implemented" includes adjustments to workflows, training, etc.
Typical Guidance: Customers in this group will attest using 2014
certified technology against either the 2014 Stage 1 or Stage 2 criteria as
applicable for their 2014 stage.
Although we have identified common scenarios, we understand your
situation may vary. We strongly advise you to attend our webinar this Friday,
September 5, in which we will provide additional guidance for your
Meaningful Use preparations for 2014. Please review the CMS resources
noted above prior to the webinar.
CMS Final Rule on MU2014
Flexibility: Implications for CPS and CEMR customers
DATE:
September 5, 2014
TIME: 10:00AM PDT | 1:00PM EDT
Registration will be required to join the event. We will record the
meeting and post it to the service portal for those who
cannot attend live.
Thank you for the opportunity to support you during this time of unprecedented
industry change.
Sincerely,
Peter Kinhan,
Vice President and General Manager,
Ambulatory Practice Solutions
GE Healthcare IT