2015 Edition FAQ

2105 Edition FAQ

With thousands of Health IT product tests under our belts, Drummond has valuable insight to offer our clients. We’ve compiled a list of the most frequently asked questions about the 2015 Edition criteria, MACRA requirements, and secure messaging, and are eager to share this knowledge with you.

2015 Edition EHR Frequently Asked Questions

  • Your 2014 certified EHR technology can be used for meaningful use attestation through 2017. Effective Jan 1, 2018 all EPs attesting for meaningful use, regardless of stage, will be required to use Health IT software certified to the 2015 edition.

  • Any type of dual certification is not technically feasible and strongly discouraged from a development and testing perspective. While some 2014 edition modules will be eligible for gap inheritance, the 2015 edition criteria is substantially different and more complex.

  • For vendors previously certified to the 2014 Edition, we estimate approximately three days to complete 2015 Edition testing based on testing for Meaningful Use (MU)-related modules only. For EHR clients with technology is not previously certified and wishing to test all MU-related, test time may be approximately four days.

  • Pricing, and other logistics related to 2015 Edition testing, including test procedures, will be finalized in 1Q2016. At that time, Drummond Group will announce the start of the 2015 Edition test and certification process via our e-newsletter. To join the Drummond newsletter list, please register here.

  • Yes. The Center for Medicaid and Medicare Services (CMS) issued a Final Rule addressing changes in Meaningful Use for 2015-2017 and establishing Stage 3 starting in 2018. There is substantial information in this rule, but the key changes are:

    • All providers and hospitals are moving to what is called Modified Stage 2 starting in 2015.
    • Reporting period for 2015 is 90 consecutive days, and the attestation period will be opening up in January 2016. Reporting periods for 2016 and 2017 are still one calendar year for returning providers.
    • Providers and hospitals will report on the same reporting period of calendar year; fiscal year will no longer apply.
    • In 2017, providers &hospitals may elect to start Stage 3, but it is not mandatory. However, if doing Stage 3 in 2017, providers &hospitals can use a 90 consecutive day reporting period instead of a full year.
    • In 2018, all providers & hospitals must start on Stage 3.
    • Both Stage 3 and Modified Stage 2 dramatically streamlined the Meaningful Use measures, including dropping those which have topped out and no longer need to be reported.
  • In 2015, ALL providers and hospitals move to what is now called Modified Stage 2, regardless of whether they were scheduled to do Stage 1 under previous CMS rules. Modified Stage 2 uses a set of 10 objectives for providers and 9 objectives for hospitals, and replaces the core and menu objective approach.

  • The CMS landing page, which outlines the 2015 program year requirements, is an excellent start. Once on that page, refer to PDF tip sheets and a recorded webinar, at the bottom, for valuable information.

  • Modified Stage 2 and Stage 3 are closely aligned. While some measures are different and some objectives have been combined, the idea is to make Modified Stage 2 closely resemble Stage 3.

  • For a better explanation of Stage 3, refer to the CMS webcast PDF slides.

  • No. 2014 Edition certifications, which “worked” in calendar year 2014 for Meaningful Use, will also work in calendar year 2015.

  • Yes. Only the new ONC criteria, 2015 Edition, can be used for Stage 3. As it currently stands in the regulation, all Health IT systems will need to be certified to 2015 Edition no later than December 31, 2017 so that providers and hospitals can do their full reporting year with their 2015 Edition CEHRT in CY 2018.

  • ONC has published the 2015 Edition Health IT Certification Criteria, which includes new, revised, and some gap-eligible criteria. Drummond Group is currently developing overview documents to help make the regulation easier to understand and more efficient for testing preparation. Once these are complete, Drummond Group will communicate the release via our e-newsletter.

  • Beginning with the 2015 Edition, “Complete EHR” certifications will no longer be issued, and only “Health IT Module” certifications will be issued. This will allow the ONC Health IT Certification Program to be more open and accessible to other Health care/practice settings. Drummond Group will be providing a certification track highlighting criteria required for the Meaningful Use Program to support vendors who have this goal.

  • The 2015 Edition Criteria uses many of the same privacy and security criteria as 2014 Edition, but also introduces two new criteria, Trust Connection (d.9) and Auditing Actions on Health Information (d.10). The full list:

    315.d.1: Authentication, access control, and authorization
    315.d.2: Auditable events and tamper-resistance
    315.d.3: Audit report(s)
    315.d.4: Amendments
    315.d.5: Automatic access time-out
    315.d.6: Emergency access
    315.d.7: End-user device encryption
    315.d.8: Integrity
    315.d.9: Trusted Connection
    315.d.10: Auditing Actions on Health Information
    315.d.11: Accounting of Disclosures

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