Issue link: https://viewer.e-digitaledition.com/i/298548
outpatient clinic and the other private practice do have certified systems, the denominator and numerator data from those practices for each measure the EP attests to must be added to the data from the primary practice to determine the percentages to be reported to CMS. The data from all the practices used in the calculations must come directly from a report generated by each of the certified systems. The report must be kept for auditing purposes for six years and should include the date it was gener- ated (within the EP's reporting period), as well as the name of the EHR product and its CMS certification number. Also, all certified systems involved must be certified for the clinical quality measures used for attestation. It is important to note that if any of the systems involves are "modular certified" and any of the core and menu measures the EP will be reporting on are not among those which the modular system is certified for, the product would not be considered certified because all reported measures must be reported from a certified EHR. Information about product certification can be obtained from the Office of National Coordinator for Health Information Technology (ONC) website. (Look for Certified Health IT Product List.) Furthermore, when an EP is attesting, a unique certification number must be used. It is provided by the ONC website by adding each certified product to your cart. In the case of the example above, there will be three products listed in the cart, and a unique certification number will be provided. Also, when a product is viewed on the ONC site, it is easy to see the features for which it is or is not certified. Finally, if a meaningful use audit is conducted, CMS will want to see a copy of the signature page of the contract, which will need to be requested from the organization that entered into the contractual agreement with the vendor. For physicians working in multiple locations, obtaining the reports with measure data from certified systems and the signed contract information will require collaboration by the healthcare organizations involved. Consequently, a good deal of advanced communication with those organizations prior to the EP's reporting period will be needed. Also, as of this writing, there is no hardship exemption from the reimbursement pen- alty available for EPs working at multiple locations who cannot obtain the measure data needed and signed vendor contracts. There are, however, physician organiza- tions advocating with CMS to put one in place. Stay tuned. John Netti is President of the EHR Advisory Gr o u p w w w.e h r a d v i s o r y g r o u p.c o m (for merly Netti Consulting Ser vices), which provides an array of EHR as well as HIPA A Privacy and Security services. For information, go to www.ehradvisor y group.com or call 315-437-4377. ■ M D N E W S . CO M ■ MD NEWS Central New York | 2 5