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EHR Attestation 

To receive an EHR incentive payment each year, you need to go through attestation with your state Medicaid office or CMS (Medicare). See Registration and Attestation on the cms.gov website.

How to avoid mistakes that could cost you money:

  1. Count on being Audited. Retain supporting documentation for at least 6 years. The audit rate for EHR is high. 
  2. Enter into an EHR contract with Open Dental. Do not apply retroactively for an EHR incentive participation year if you did not have an EHR contract for that year. 
  3. Certification for EHR is a vendor/product combination, not just a product. CMS dictates that any contract for an EHR purchase must be directly with the vendor. Thus, EHR-certified versions of Open Dental can only be purchased directly from Open Dental. You cannot purchase an EHR-certified version of Open Dental from a reseller.
  4. For AIU, make sure your AIU participation year matches the EHR contract year. 
  5. If you have accepted an incentive payment, do not cancel your Open Dental support or contract early.
  6. Make sure you meet EHR incentive program requirements before accepting payment.
  7. Reporting Meaningful Use: Don't make up numbers. If you are using Open Dental EHR as designed, your reporting will provide the accurate figures.
  8. You must comply with HIPAA requirements and have a Security Risk Analysis (SRA) in place. Do not claim you had an SRA if you did not.

Providers who make a mistake during attestation for AIU can self report and have their year changed.

Information Required during Attestation
The following information may be requested during attestation.

  1. EHR Contract: When you Purchase Open Dental EHR, we will sign a dated one-year contract with you indicating that you have purchased it. Retain this document as proof that you have adopted, implemented, or upgraded to an EHR certified software.

  2. Open Dental's 2014 Edition Certification ID number.
    a. Go to the CHPL website: https://chpl.healthit.gov/#/search.
    b. Search for Open Dental.
    c. Click +Cert ID next to the correct version. Open Dental will be added to the CMS EHR Certificate ID dropdown in the upper right.
    d. Click Get 2014 EHR Certification ID. It should be one of the following:

    Version 14.2: A014E01O2O9JEAR
    Version 14.3: 1314E01PO9HJEAL
    Version 15.1: 1314E01Q9FVEEAB
    Version 15.2: 1314E01QOS2QEAX
    Version 15.3: 1314E01R9MCPEAZ
    Version 15.4: 1314E01RMRKUEAT
    Version 16.1: 0014EYA83N7UQP5
    Version 16.2: 0014EY3VFJ1UCV3
    Version 16.3: 0014E5H68QZ2EKZ

    e. Click Download PDF to save a PDF version of the CHPL entry to submit as part of the attestation process.

  3. Proof of Eligibility:  Some states have requested reports that demonstrate program eligibility. See EHR Eligibility Queries to calculate Medicaid percentages and patient volume.

  4. Meaningful Use: If attesting for meaningful use, gather the following information for the reporting period. It should identify the time period, prove that it is generated for the provider, and identify the software used.
    • Numerators, denominators, and percentages for EHR Modified Stage 2 measures. See EHR Measure Reports.
    • Evidence that supports or explains any exclusions claimed.
    • Additional supporting documentation such as date-stamped screenshots, reports, or acknowledgements that support yes/no and other objectives.
    • Clinical Quality Measure numerators, denominators, and percentages: See Report Clinical Quality Measures.

Hints: 

  • Retain all supporting documentation for at least 6 years in case of audit.
  • We recommend you create an EHR folder and store all supporting documentation in one place for easy access. See also: CMS Supporting Documents for Audits.
  • If supporting documentation includes Query results, you may want to include identifying header information on the end report. To add a title, save the query to your Query Favorites, then enter a Title that includes all identifying information (e.g. title, date ranges, provider). Then run the query again.
  • 2016 Attestation Worksheet (PDF)

 

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