6/29/2017: Please note that this article was published in 2011 & pertains to MU Stage 1. It’s not relevant to current Stages 2,3 & MIPS.
You should be able to find the answers to most questions in the 63 page CMS attestation
guide by visiting two screens in ECLIPSE. If you’re unfamiliar with the term “Meaningful Use,” read a brief overview here. Though it shouldn’t be necessary, an educational CMS video that explains the process step-by-step can be viewed here. You can also read a CMS FAQ document here. Finally, you must enroll with PECOS prior to registering on the CMS website. You can enroll here. A 2015 updated CMS “tip sheet” is available here with the most current information.
- From the Reports menu, select Patient List. Press F1 for HELP and read about Automated Measure Calculation. This section contains extensive instructions on each and every Meaningful Use measure, how you can meet the requirement in ECLIPSE, and how you can check which patients meet the criteria for that measure for high percentage measure requirements.
- From the Reports menu, open the Audit folder, and select NQF/PQRS Measures. Press F1 for HELP and read detailed information about each of the measures, how they’re assessed for different patient populations, and how you can get the information you need to manually enter the numerator and denominator values for the measures you choose.
It seems many of you remain confused about some of the other information in this guide.
So, let’s start with security. Bear with me since I’m handling these out of order… Let’s review (15 of 15) on page 28 of the guide. You must attest that you have
conducted a review or security analysis per 45 CFR 164.308(a)(1) and have implemented security updates as necessary, corrected security deficiencies as part of your risk management process.
Now, ECLIPSE is certified as a “Complete EHR.” Therefore, it’s certified on all the security measures. Ergo, you can’t implement ECLIPSE in a non-secure way. Hopefully, since the implementation of HIPAA, you’ve regularly reviewed your office security protocols to avoid potential HIPAA violations. So, you should simply be able to indicate “Yes” to the measure. Read more about the security measure and audits here.
Next, let’s discuss steps 8 & 9. Step 8 indicates:
“Implement drug-drug and drug-allergy interaction checks.”
Step 9 indicates
“Maintain an up-to-date problem list of current and active diagnoses.”
First, I should point out a very important difference between these two steps. ECLIPSE tracks “step 9” for each of your patients. This step, as you can see on page 19 of the guide, requires a numerator and denominator. In other words, Step 9 has a reporting requirement – step 8 does not.
Let’s pursue a tangent for a moment. As an example, consider email access in ECLIPSE. ECLIPSE can send email, text messages, or bulk email on demand. In fact, the various email features of ECLIPSE are enabled whether or not you have an email account or use the internet. In contrast, consider that your ability to provide educational materials must be specifically enabled by us for your office (we reprogram your sentinel to allow access as per our agreement with the content provider).
Now, if you’re a chiropractor, and you don’t prescribe or review your patient’s drug
regimens, features relevant to step 8 are enabled in ECLIPSE regardless of whether you subscribe to prescription services. Of course, like email, if you want to actually use these features of your program (which you’re welcome to do), you must setup an
account with the service provider.
Note: This blog entry was originally created in 2011, and DHHS has since clarified requirements to the extent that all subscriptions required by your certified technology must be maintained by providers seeking incentive payments under MU guidelines.
This is actually a good opportunity to touch upon a related subject. Some of the items we report on are part of the normal HIPAA audit trail we maintain for your patient data. Thus, when you send an email from a patient’s folder, we track it. When you open that patient’s folder, we track it. When you add a problem, we track that too. Our audit trails have helped prosecutors bring convictions, and I’ve personally become involved in audits & investigations across the country where the audit trails we maintain have occasionally helped protect targeted health care providers. Now, since I’ve been discussing steps 8 & 9, this would be a good time to point out that there is absolutely no verbiage or requirement whatsoever with regard to Stage I auditing (by you or us) of an item such as “Implement drug-drug and drug-allergy interaction checks.” If you’re concerned about fraud, don’t claim you’re using a certified version of ECLIPSE when you’re running a copy that’s actually several years old. That will catch up with you by next year.
Most of the remaining parts of the guide are reasonably straightforward and can be handled by referencing the HELP as noted above. It’s unfortunate that some of the existing verbiage has created unreasonable concerns among some health care providers — which isn’t helped by the many “consultants” who like to lecture on the subject. (See my discussion of Medication Reconciliation as an example.) It’s beginning to remind me of 1999, when doctors I know were raiding their bank accounts to make sure they had cash when the banks failed as part of the Y2K debacle. Of course, if all the banks failed, who would actually have any use for cash? We’d be back on the barter system.