EHR: Before You Begin a Reporting Period

On October 1, 2018, CMS released a new Final Rule for the EHR/PI Incentive Program. The rule requires the use of 2015 edition certified electronic health record technology (CEHRT) to attest for Program Interoperability Stage 3 beginning in Calendar Year 2019. Open Dental has decided not to develop a certified 2015 edition software and will not be supporting attestation for years after 2018.

Once you begin an EHR meaningful use reporting period, every entry and calculation will count. Preparation is the key to success.

Before you start your first reporting period with Open Dental, we recommend a minimum of 1 -2 months for preparation:

See our video playlist: EHR Webinars.

Preparing to attest

  1. Renew your EHR contract for the current year. (PDF)
  2. Update to the most current EHR-certified version of Open Dental so you have access to the most recent EHR enhancements.
  3. Understand meaningful use requirements.
    • Review the objectives, measures and threshold requirements. See EHR Modified Stage 2.
    • Review the EHR Clinical Quality Measures.
    • Identify additional supporting documentation that may be required to prove you have met MU objectives that are not percentage-based (e.g. dated screen shots). Some information may need to be collected prior to, at the beginning of, in the middle of, or at the end of the reporting period. You will need to keep all documentation for 6 years in case of audit.
  4. Ensure your practice is HIPAA-compliant; conduct a Security Risk Analysis. Protecting electronic health information is required by HIPAA and for meaningful use. It entails conducting a Security Risk Analysis to identify which security policies and procedures are in place and risks that need to be addressed. The analysis must be documented in a security risk analysis report. Conduct the review prior to, or during, your first reporting period and then again for each subsequent reporting period. For security risk analysis guidance and resources, see HIPAA, Security Risk Analysis.
  5. Set up Open Dental for EHR. Some options in Open Dental must be setup BEFORE you begin a reporting period. Complete all set up steps. This will ensure accurate EHR measure reports and CQMs. See EHR Setup.
  6. Train your staff. Educate your staff on EHR requirements and work flow processes. To help, several free webinars are available.
  7. Practice entering MU data for patients. To get a feel for what you need to do, and the effort it will take, start entering MU data for patients. Don't start your reporting period yet. Instead, see how you are doing by regularly reviewing EHR Measure Reports. Once you are in the habit of entering the required data, and your percentages regularly meet requirements, proceed to the next step.
  8. Begin your reporting period. Once you are confident you can demonstrate MU for objectives and measures, begin your reporting period.
  9. Attest. When your reporting period is complete, run EHR Measure Reports and Clinical Quality Measures (CQMs) to compile your data and gather supporting documentation, then attest to receive your incentive payment. Each state varies in the specific information required. At a minimum, you will need to provide denominators, numerators, and percentages for measures. You may also need to provide other supporting documentation (e.g. for yes/no measures).