The Attestation Experience

This morning at 8am the CMS attestation website went live.

At 8:30am, I completed the attestation for Beth Israel Deaconess Medical Center.

Here's an overview of the experience.

At the top of the Attestation page, you'll see the link "Click here to attest."

Once in the Medicare & Medicaid EHR Incentive Program Registration and Attestation System you need to choose Eligible Hospitals or Eligible Professionals.   I chose Eligible Hospitals and logged in with the same user ID and password we used to register BIDMC.

1.  You're asked to enter your EHR Certification Number from the Office of the National Coordinator.  This is an interesting concept, because the EHR Certification number is not the same as the Certified Healthcare IT Product List (CHPL) Product number assigned during the certification process.  For example, the BIDMC Online Medical Record was assigned a CHPL Product Number of CC-1112-549900-1 during the CCHIT EACH certification process.

To obtain an EHR Certification Number, go to the CHPL Website.

Click on Ambulatory or Inpatient.   I clicked on Inpatient.

I searched by product name for BIDMC's "Online Medical Record".

I clicked Add to Cart.   Do this for all the products you need to meet 100% of the Certification Criteria.  Note that there is a bug in the CHPL page.  See Keith Boone's blog for the workaround.

Once you've achieved 100% of the required criteria, you can click on "Get CMS EHR Certification ID" in the View Cart area.  I was assigned a CMS EHR Certification ID of 30000001TMQOEAC

2.  Next you must specify if you've chosen to count all ED visits or use the "observation services" method for calculating ED visits. This includes ED patients admitted to inpatient or observation services and excludes ED patients discharged from the ED.  We used the observation services method.

3.  Next you attest to the Core Criteria.  Here's a copy of my completed submission.   Of interest, no patient requested an electronic copy of their discharge instructions or an electronic copy of their lifetime record.   Our software has the ability to generate these, but since no patient asked for them during the reporting period, the denominator was zero and no numerator needed to be reported.

4. Next you attest to the Menu Set Criteria.  Here's a copy of my completed submission.   We've tested immunizations transactions with the Department of Public Health sent via secure FTP.  We've tested lab results and syndromic surveillance with the Boston Public Health Commission sent via NEHEN.   Formulary enforcement is included in all our ordering systems.   We have numerous screening sheets and business intelligence tools that generate patient lists based on clinical criteria.

5. Next you attest to the 15 hospital quality measures.  Remember that the ED measures include stratifications for admitted, observation, and psychiatric patients.  The numerators of the ED measures are times measured in minutes.  For all other quality measures you must provide numerators, denominators and exclusion measures using patient counts.   In 2012, CMS will require these measures to be submitted electronically using PQRI XML.   I look forward to the automation of this step, since manually entering more than 50 numbers accurately was challenging.

6. Once you've completed the core, menu set, and quality measures, you're asked to answer a series of questions attesting to the accuracy of your submissions and your authority to perform the attestation.

If you've met all the criteria successfully, your attestation is approved and a submission receipt page appears (the graphic above). Print or save this receipt since it is not emailed to you.

That's it.  It should take 30-60 minutes to complete if you have all your data handy.    I welcome comments on the attestation experience of others so that the Healthcare IT Standards Committee Implementation Workgroup can provide input as Stage 2 is planned.