Attestation for Stage 1 Meaningful Use can be testy when there is confusion on the requirements. Case in point is the capability to exchange key clinical information, a core measure requirement for both Eligible Professionals and Eligible Hospitals.
To start, I think we’re all clear on what is meant by “key clinical information”. Problem lists, medication lists, medication allergies, and diagnostic test results, etc. It is also clear that this measure cannot be excluded. It is also obvious that what is required is the attestation that the EP or EH has “performed at least one test of certified EHR technology’s ability to electronically exchange key clinical information”. So what is this business about “electronically exchange”? Is it OK to copy the health information to a thumb drive or CD and carry it from one EHR to another and import the file? What about faxing or emailing the clinical information and importing it some way to another system?
CMS has finally provided clarification and guidance that rules out the use of any physical media for this measure. Additionally, CMS says that “exchange is defined as electronic transmission and acceptance of key clinical information”. And by the way, that data is expected to be structured except for free text or scanned images. Go here for CMS clarification to learn more.
One interesting final twist on this measure is that: “An unsuccessful test of electronic exchange of key clinical information will be considered valid for meeting the measure of this objective.”
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Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. As one hospital CEO stated, “we were notified by CMS that the adverse audit decision was being overturned and we did not have to return the 2011 EHR Incentive Payment. I would recommend the services of Mr. Tate and EMR Advocate in the event your facility is notified that it will be subject to a Meaningful Use audit or your facility is audited, or you have an adverse outcome and need to file an appeal." He blogs at Meaningful Use Audits. If you are a hospital with a question about the MU audit and appeal process, email him at: [email protected]
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