To be eligible for payments under the American Recovery and Reinvestment Act, which funded the Medicare EHR inventive program, according to the CMS, hospitals must pledge that the information they submit and attest to is:
- accurate to the knowledge and belief of the hospital or the person submitting on behalf of the hospital;
- accurate and complete for numerators, denominators, exclusions and measures applicable to the hospital;
- includes information on all patients to whom the measure applies, and;
- for the portion of the criteria known as clinical quality measures, was generated as output from an identified certified EHR technology.
“By agreeing to the above statements, the hospital is attesting to providing all of the information necessary from certified EHR technology, uncertified EHR technology, and/or paper-based records in order to render complete and accurate information for all meaningful use core and menu set measures except CQMs,” the CMS guidance said.
For clinical quality measures, though, what an EHR system outputs is good enough for the CMS, according to the guidance.
“CMS considers information to be accurate and complete for CQMs to the extent that it is identical to the output that was generated from certified EHR technology,” the guidance said. “In other words, the hospital is only attesting that what was put in the attestation module is identical to the output generated by its certified EHR technology. Therefore, the numerator, denominator, and exclusion information for CQMs must be reported directly from information generated by certified EHR technology.”
The first year of the Medicare program for hospitals began Oct. 1, 2010. Hospitals had until Sept. 30, 2011, to complete 90 consecutive days of compliance with Stage 1 meaningful-use criteria. Hospitals will have up to 60 days after that deadline to submit needed data. The CMS began accepting attestation for Stage 1 meaningful use April 18, 2011, but it's expected a wave of hospitals will seek to qualify for incentive payments now that the first program year has ended.
“I don't see anything in here that is new, different,” said Dave Roberts, vice president of government relations, for the Chicago-based Healthcare Information and Management Systems Society. The CMS “just wanted to make sure everyone understood this attestation process. This is just clarifying what it is all about.”