According to The Centers for Medicare and Medicaid services (CMS), by the start of 2019, hospitals will be required to use 2015 certified EHR technology. Though, ample time is given for the implementation, there are some major challenges up ahead for the certification, especially when it comes to the thresholds of meeting some of the MU3 information exchange attestation and objectives. From ensuring data security to the documentation, MU3 certification has been proved not to be a piece of cake. And, to add to it, CMS is very specific about the standards, the requirements and measures for MU3 Certification.
65% of the certification is focused primarily on the implementation of three standards.
- Consolidated Clinical Document Architecture (C-CDA)
- Quality Reporting Document Architecture (QRDA)
- Application Programming Interfaces (API)
With the newer version for C-CDA and QRDA implementation, the XML generation became more structured and the base line identified was the same for all HL7 standards. This baseline ensured the building of the C-CDA and QRDA XML on the same bridge by re-using the base classes.
A Common data binding platform and Reusable Base components help to ease development and faster generation of XMLs.
Confused about the tools?
Worry no more!
During the upgradation of clinical coding, the major hurdle is the implementation of the tool dependent measures. Validation tools ensure accuracy in data entry and generation for all the relevant measures. The major challenge was with the Cypress tool, in the implementation of importing, calculating and generating a QRDA file while ensuring the de-duplication logic is executed. The tool also underwent a major version upgrade in mid-October, making it more stringent, during the certification process for numerous EHRs.
Is the workflow getting impacted?
The show must go on!
Making sure that Workflow is not being impacted is an important task during the implementation. Complying with MU3 standards for an in-use EHR is tricky as one need to ensure the implementations complement the physicians’ workflow and the application follows the relevant coding standards. It is important to blend the features of MU3 in your products such that it adds value to the current product and helps providers score better in the regulatory/ quality programs.
Ensured Data Security?
Security first!
Data breach is always a concern in any platform which has important data to deal with.
MU3 Certification enables healthcare providers and patients confident that the Electronic Health IT products and systems they utilize are secure, can keep information secure, and work with different systems to share data.
Two-way process to ensure Data Security:
- CDA generators, CQM calculators, Patient Portal and APIs, all being independent applications need to implement Network Time Protocols to synchronize their times for consolidated audit results.
- Any files stored on local instances should not be left unencrypted.
How to tackle MU3 documentation?
Early bird has it all!
With all the documents to be dealt with during the certification, it is bound to drive you insane. Sooner you deal with them, easier it gets. Start with the documents early, so it won’t pile up at the end.
Here are some key highlights to manage documentation:
- EHRs need to submit the measures which they would like to self-disclose and also to keep a copy of screenshots once the measure is implemented.
- Quality Management System now imposes EHRs to follow a standard or map the complete workflow with the standard.
- The GAP measures need to be properly filled to ensure there are no technical implementation changes to the measures already certified in Stage II.
- Some documentation, such as screenshots of automated measure calculations for every required test, is to be sent to the proctor before the certification date.
MU3 Certification has a lot of challenges but it need not be a nightmare if you understand the processes and plan it well with the help of experts.
We will be sharing a certification management handbook and an optimized workflow for a hassle free certification process in the coming weeks.
Vijayalaxmi Kudekar
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