CMS Announces July 2015 Transition from IACS to EIDM


The Centers for Medicare & Medicaid Services (CMS) would like to inform Physician Quality Reporting System (PQRS) participants and their staff to an important system update scheduled to be in place on July 13, 2015.

The Individuals Authorized Access to CMS Computer Services (IACS) system will be retired, but current IACS user accounts will transition to an existing CMS system called Enterprise Identity Management (EIDM). The EIDM system provides a way for business partners to apply for, obtain approval, and receive a single user ID for accessing multiple CMS applications.

Existing PQRS IACS users, their data, and roles will be moved to EIDM and will be accessible from the ‘PQRS Portal’ portion of the CMS Enterprise Portal at Users will then access the PQRS Portal to submit data, retrieve submission reports, view feedback reports, or conduct various administrative and maintenance activities. New PQRS users will need to register for an EIDM account.

Stay tuned for more information and resources in the coming weeks and months! In the meantime, please ensure that your IACS account is active, current, and you’re able to log in. This will help ensure a smoother transition to EIDM.

For additional assistance regarding IACS or EIDM, contact the QualityNet Help Desk at 1-866-288-8912 (TTY 1-877-715-6222) from 7:00 a.m. to 7:00 p.m. Central Time Monday through Friday, or via email at To avoid security violations, do not include personal identifying information, such as Social Security Number or TIN, in email inquiries to the QualityNet Help Desk.

CMS Announces Extension for EPs participating in PQRS via EHR and QCDR (QRDA III format)

The Centers for Medicare & Medicaid Services (CMS) is pleased to announce that the submission deadlines for the PQRS reporting methods below have been extended.  All other submission timeframes for other PQRS reporting methods remain the same.  The revised submission timeframes are:

Reporting Method Submission Period Submission Deadline Time

(All Times are Eastern)

EHR Direct or Data Submission Vendor that is certified EHR technology (CEHRT) 1/1/15 – 3/20/15 8:00 p.m.
Qualified clinical data registries (QCDRs) (using QRDA III format) reporting for PQRS and the clinical quality measure (CQM) component of meaningful use for the Medicare Electronic Health Record (EHR) Incentive Program 1/1/15 – 3/20/15 8:00 p.m.

An Individuals Authorized Access to CMS Computer Services (IACS) account with the “PQRS Submitter Role” is required for these PQRS data submission methods. Please see the IACS Quick Reference Guides for specifics.

PQRS provides an incentive payment to individual eligible professionals (EPs) and group practices that satisfactorily participate or satisfactorily report data on quality measures for covered Medicare Physician Fee Schedule (PFS) services. Additionally, those who do not meet the 2014 PQRS reporting requirements will be subject to a negative payment adjustment on all Medicare Part B PFS services rendered in 2016.

Note:  The deadline listed above does apply to Individual Eligible Professionals and Group Practices participating in other CMS programs such as the Medicare EHR Incentive Program and Comprehensive Primary Care Initiative that are utilizing the reporting methods listed above. Additionally, CMS has extended the deadline for EPs wishing to attest to meaningful use for the EHR reporting period in 2014 for the Medicare Electronic Health Record (EHR) Incentive Program to March 20, 2015. Please be on the lookout for a separate listserv with information regarding the attestation extension.

For questions, please contact the QualityNet Help Desk 1-866-288-8912 or via email at from 7:00 a.m. – 7:00 p.m. Central Time. Complete information about PQRS is available at

Using templates in your EHR? Make sure they are updated for ICD-10!

The follow article, written by Cathie Wilde pertains to any EHR that is “template driven”.  As we approach (hopefully) adoption of ICD-10 codes, looking at how your templates are coded is one of those great first steps a practice can take to begin it’s transition to ICD-10.

 Published from ICD-10 monitor:
 “Templates can either enhance documentation necessary for coding and data quality, or they can hinder things by restricting options and failing to prompt physicians to document specific information. However, templates cannot be overlooked when it comes to ICD-10. This is particularly true if a hospital relies more heavily on templates to capture structured data. Many hospitals may use templates for certain diagnoses, orders, or visit types and allow physicians to dictate information for everything else.

Regardless of a hospital’s specific use of templates, one point remains clear: the templates must be updated to accommodate the details necessary for ICD-10. At a minimum, these details include laterality, specificity, and etiology. The number of physicians who could be using a specific template at any given time — or even over a short period of time — could be significant. If one template is not updated correctly to accommodate ICD-10, data quality and reimbursement could be compromised.

Health information management (HIM) directors cannot assume that electronic health record (EHR) vendors will handle this effectively and in a timely manner. Instead, take the following steps to ensure that all updates will be made:

1. Take an inventory of all current templates in use. Are some of these templates used more frequently than others? Can any of them be retired if not in use? Ask for input from coders — what information is typically missing from the templates? Can you add or revise this information during the ICD-10 update? Work with your EHR vendor to make these changes before tackling ICD-10 updates.

2. Form a committee to address ICD-10 template updates. This committee, which can be a subcommittee of the ICD-10 implementation committee, should include coders, clinical documentation improvement (CDI) specialists, a physician champion, and an EHR representative. Compile a list of all diagnoses and procedures that require greater specificity in ICD-10 and cross-check this list with any templates that are in use. Ensure that each and every reference to these diagnoses and procedures is updated to accommodate ICD-10 specificity and other requirements.

3. Tie your template update efforts to your query update efforts. As CDI specialists review queries to ensure the implementation of updates for ICD-10, they can easily use this information to review templates in light of ICD-10 changes. If templates ultimately capture all of the relevant information that coders need, a query may not even be necessary.

4. Review templates after updates have been made. Set a deadline for all template updates to be completed. Then manually review each template to ensure that updates have been entered correctly.

5. Educate physicians. Physicians don’t need template-specific training; however, let physicians know that the updated templates exist when performing specialty-specific ICD-10 training. Reiterate that the templates exist to make physicians’ jobs easier by prompting them to document what’s necessary and pertinent to ICD-10 in the most concise way.

Clinical areas for review

Consider focusing on the following templates that require new and more specific documentation in ICD-10:

Obstetrics-related templates

  • Specific trimester: The majority of codes in Chapter 15 (Pregnancy, Childbirth, and the Puerperium) feature a final character that indicates the trimester of the pregnancy. Assignment of this character is based on the provider’s documentation of the patient’s trimester during the admission/encounter. Templates should include the weeks of gestation at the time of admission and/or delivery.
  • Fetus identification: ICD-10 requires a seventh character to denote multiple gestations, when applicable. This character identifies the fetus for which the complication code applies. Templates should provide an option for this character.
  • Multiple gestation placenta status: ICD-10 features a combination code for multiple gestation and identification of the number of placentas and amniotic sacs. Templates should capture this information as well.

Trauma-related templates

  • Glascow coma scale: This scale denotes the degree of consciousness and is used commonly with head trauma cases. The score can function as an indicator for testing or treatment as well as predict the duration and outcome of the coma. Templates for head injuries should specifically include this information.
  • Gustilo classification: This classification applies to open fractures of the long bones, including the humerus, radius, ulna, femur, tibia, and fibula. The classification system groups open fractures into three main categories and three subcategories defined by these characteristics: mechanism of injury, extent of soft tissue damage, and degree of bone injury or involvement. Templates for open fractures should include this information.
  • Salter-Harris classification: This classification includes nine types of fractures that occur along the epiphyseal (growth) plates in bones that have not reached full maturity. With these types of fractures, plates are still open and filled with cartilaginous tissue. These fractures are common among children. Templates for these fractures should include information related to the Salter-Harris classification system.

Wound-related templates

  • Severity: In addition to specific location and etiology of non-pressure skin ulcers, ICD-10 also requires physicians to document the severity of the ulcer as follows:
    • Limited to breakdown of skin
    • With fat layer exposed
    • With necrosis of muscle
    • With necrosis of bone

Any and all wound templates should include these designations. Pressure ulcer templates should continue to include the stage of the ulcer.

Nutrition templates

  • Obesity: In addition to the current body mass index documentation on nutrition orders/templates for obesity, ICD-10 includes additional codes for obesity due to excess calories, drug-induced obesity, and morbid obesity with alveolar hypoventilation. Templates should be updated to include these designations. “

About the Author

Cathie Wilde, RHIA, CCS, is the director of coding services for MRA. Ms. Wilde has been active in the healthcare industry for more than 30 years. Her previous positions have included assistant director of HIM, DRG coordinator at the Massachusetts Hospital Association, and DRG validator at Blue Cross Blue Shield. She has extensive experience in ICD-9-CM and CPT coding, auditing, data analysis, development and testing of coding products, specialized reporting, and in-service training. As director she is responsible for overseeing the coding division, providing the strategic direction of MRA as a local industry leader of quality coding, auditing, and denial management services. Ms. Wilde is an American Health Information Management Association (AHIMA)-approved ICD-10-CM/PCS trainer.

New CMS rule allows flexibility in certified EHR technology for 2014

The Department of Health and Human Services (HHS) published a final rule on August 29, 2014, that allows health care providers more flexibility in how they use certified electronic health record (EHR) technology (CEHRT) to meet meaningful use for an EHR Incentive Program reporting period for 2014. By providing this flexibility, more providers will be able to participate and meet important meaningful use objectives like drug interaction and drug allergy checks, providing clinical summaries to patients, electronic prescribing, reporting on key public health data and reporting on quality measures.

“We listened to stakeholder feedback and provided CEHRT flexibility for 2014 to help ensure providers can continue to participate in the EHR Incentive Programs forward,” said Marilyn Tavenner, CMS administrator. “We were excited to see that there is overwhelming support for this change.”

Based on public comments and feedback from stakeholders, the Centers for Medicare & Medicaid Services (CMS) identified ways to help eligible professionals, eligible hospitals, and critical access hospitals (CAHs) implement and meaningfully use Certified EHR Technology. Specifically, eligible providers can use the 2011 Edition CEHRT or a combination of 2011 and 2014 Edition CEHRT for an EHR reporting period in 2014 for the Medicare and Medicaid EHR Incentive Programs; All eligible professionals, eligible hospitals, and CAHs are required to use the 2014 Edition CEHRT in 2015.

These updates to the EHR Incentive Programs support HHS’ commitment to implementing an effective health information technology infrastructure that elevates patient-centered care, improves health outcomes, and supports the providers that care for patients.

The rule also finalizes the extension of Stage 2 through 2016 for certain providers and announces the Stage 3 timeline, which will begin in 2017 for providers who first became meaningful EHR users in 2011 or 2012.

See the full press release here:

See the EHR Incentive Programs 2014 CEHRT Ruke: Quick Guide here:

See the CEHRT Flexibility Decision Tool here:

Kelly Meeks

Sunrise Services, LLC

Does the July 1, 2014 MU deadline apply to you?

Are you a bit confused on whether or not you should file an exception this year?  And what about that July 1, 2014 “deadline” fast approaching? 

With so much money…..both in incentives received and fear of losing money due to audits and penalties, we’ve summarized some information surrounding this “deadline” and what it may (or may not) mean for you and your practice.

New participants in 2014

If you are new to the program and intended to demonstrate meaningful use for the first time in 2014, but you are not able to implement 2014 certified EHR technology for the 2014 reporting year, you may apply for a hardship exception for the 2015 payment adjustment.  

An interactive tool is available to help you determine if you will avoid upcoming 2015 and 2016 Medicare EHR Incentive Program payment adjustments by demonstrating meaningful use, or if you should apply for a hardship exception.  The deadline to do this is JULY 1, 2014.  Please bear in mind that if you are a returning eligible professional, you will not need to file an exemption for 2014.

Applying for Hardship Exception When submitting hardship exception applications, entries must include supporting documentation that proves demonstrating meaningful use presented significant hardship.

CMS has posted hardship exception applications on the EHR website for:

Please read and follow the submission instructions on the application. Note that all required supporting documentation must be included at the time of submission. Completing your application online and submitting it electronically to, with all required supporting documentation, will reduce the application processing time. Please do not submit hand-written applications.

Hardship Exception Tip sheets You can also avoid payment adjustments by successfully demonstrating meaningful use prior to the payment adjustment.  Tip sheets are available on the CMS website that outline when eligible professionals must demonstrate meaningful use in order to avoid the payment adjustments.

Returning meaningful users in 2014

If you successfully demonstrated meaningful use for the 2013 reporting year, you will not be subject to the 2015 payment adjustment.  If you are not able to implement 2014 certified EHR technology for a 2014 reporting period, you may apply for a hardship for the 2016 payment adjustment.

  • Use the eligible professional hardship exception for 2016 which will be available after July 1, 2014
  • Indicate that you are applying for a hardship because of 2014 vendor issues
  • Submit your application by July 1, 2015

 Want more information about the EHR Incentive Programs? Make sure to visit the Medicare and Medicaid EHR Incentive Programs website for the latest news and updates on the EHR Incentive Programs.

Why this doctor loves electronic medical records

Medisoft Clinical is a fully integrated EMR system.

Dr. Jen Gunter

There is a recent and interesting piece in the Washington Post by an orthopedic surgeon, Dr. Craviotto, about the maddening aspect of forced mandates and bureaucratic requirements in medicine that seem to have very little to do with actual medical care and more about hoops through which we must jump that seemingly lead to nowhere.

While I do find the bureaucracy of medicine in the United States insane versus the Canadian system (for example) I was interested in Dr. Craviotto’s take on the burden of the forced electronic health record (EHR) mandate and the time that doctors spend filling out “unnecessary fields” to satisfy regulatory measures. Dr. Craviotto writes that his isn’t an unique complaint, quoting a study commissioned by the American Medical Association that identified “Poor EHR usability, time-consuming data entry, interference with face-to-face patient care, inefficient and less fulfilling work content, inability to exchange health information between EHR products, and…

View original post 1,518 more words

New EHR Attestation Deadline

New EHR Attestation Deadline for Eligible Professionals:
March 31, 2014

CMS is extending the deadline for eligible professionals to attest to meaningful use for the Medicare EHR Incentive Program 2013 reporting year from 11:59 pm ET on February 28, 2014 to 11:59 pm ET March 31, 2014.
In addition, CMS is offering assistance to eligible hospitals who may have experienced difficulty attesting to submit their attestation retroactively and avoid the 2015 payment adjustment.
This extension will allow more time for providers to submit their meaningful use data and receive an incentive payment for the 2013 program year, as well as avoid the 2015 payment adjustment.
This extension does not impact the deadlines for the Medicaid EHR Incentive Program or any other CMS program, including the electronic submission for the Physician Quality Reporting System EHR Incentive Program Pilot.

How to attest?
If you are an eligible professional, you may use the registration and attestation system to submit your attestation for meaningful use for the 2013 reporting year. You must attest prior by 11:59 pm ET on March 31, 2014 to meet the new 2013 program deadline.
If you are an eligible hospital, you may contact CMS for assistance submitting your attestation retroactively. You must contact CMS by 11:59 pm on March 15, 2014 in order to participate for the 2013 program year.

If you are an eligible professional working on your attestation for the 2013 reporting period, there are resources available to help you with the registration and attestation process.
Stage 1 Meaningful Use Calculator
Registration and Attestation User Guides
EHR Incentive Program Website
The EHR Information Center is open to assist you with all of your registration and attestation system inquiries. Please call, 1-888-734-6433 (primary number) or 888-734-6563 (TTY number). The EHR Information Center is open Monday through Friday from 7:30 a.m. – 6:30 p.m. (Central Time), except federal holidays.

In addition, there are some simple steps you can take which will help to make the process easier for you:
• Ensure that your payment assignment and other relevant information is up to date in the Medicare payment system PECOS
• Make sure to include a valid email address in your EHR program registration
• Consider logging on to use the attestation system during non-peak hours such as evenings and weekends
• Log on to the registration and attestation system now and ensure that your information is up to date and begin entering your 2013 data
• If you experience attestation problems, call the EHR Incentive Program Help Desk and report the problem
• If your organization has more than 1,000 providers assigned to a proxy user, use the PECOS system to designate additional proxies to facilitate attestation.

Eligible Hospital Instructions:
1. Send the following information to no later than 11:59 PM EST on 3/15/2014:
o Hospital Name
o Contact Person Name
o Contact Person Email
o Contact Person Phone
2. Type “EH 2013 EXTENSION” in the subject line of the email note
3. Each Hospital must be identified in a separate email
CMS will contact the person that you designate in your request to provide additional instructions regarding the Eligible Hospital 2013 attestation submission.

Other changes for 2014

sunriselogo2009With all the chatter going on with ICD-10, I thought it appropriate to write something that doesn’t revolve around ICD-10.  There are changes in Meaningful Use stage 1, and new criteria for Stage 2 Meaningful Use, Clinical Quality Measures and PQRS.  Happy reading!

If you have attested for at least 2 years for stage 1 meaningful use, then stage 2 is next on the docket for your practice. If you have attested once for stage 1 then all those things you attested to before now will change this year. Stage 1 requirements change in 2014 as well as Stage 2 Meaningful Use objectives for those of you who have successfully completed two years of Stage 1.

 Let’s first tackle those changes in 2014 to Stage one Meaningful Use:
1. Electronic Health Record (EHR) software systems have to re-certify their product to meet new regulations for 2014. Right now your current EHR has undergone the certification process for 2014 and will be available early spring of 2014.
2. For those of you that plan on doing stage 1 in 2014, certain “core” and “menu” objectives have been removed/combined and you can no longer count measure exclusions toward meeting menu objectives. You will have to meet 5 of the 9 menu items and 13 (as opposed to 15 in previous years) core objectives.
3. Clinical Quality Measure reporting will change as well. You will have to report on 9 and those 9 need to cover at least 3 of the 6 National Quality Strategy Domains. I’ve explained more later on.
4. Reporting is done in one calendar quarter, as opposed to 90 consecutive days previously (for example, April 1 2014- June 30, 2014). Rules for Medicaid incentive have not changed for 2014 so you can report for any continuous 90 days under Medicaid.
5. This is the last year you are eligible to begin to get incentive payments. If you are planning to start your first year this year you can still earn as much as $24,000 in incentives. AND your meaningful use performance in 2014 will be the basis for 2016 payment adjustments.
6. CPOE Denominator changes-now required (you will not be able to exclude from this measure).
7. Vital sign age limit is 3 years and older (changed from 2 years and older) for blood pressure and no age limit on height and weight. Since BP is separate, you can exclude from the BP measure.
8. The old stage 1 requirement for providing patients with an electronic copy of their health information upon request will be changed in 2014 to “Provide patients the ability to view online, download and transmit their health information within 4 business days of the information being available to the EP”.
9. The old stage 1 requirement for providing patients timely electronic access to their health information within 4 business days will be changed in 2014 to “More than 50 percent of all unique patients seen by the EP during the EHR reporting period are provided timely (within 4 business days after the information is available to the EP) online access to their health information subject to the EP’s discretion to withhold certain information”.

Moving on to what is next with Stage 2 Meaningful Use.

Stage 2 retains the same basic structure as Stage 1; however, all those Menu items in stage 1 become CORE items for Stage 2 with higher thresholds that you must achieve. There are also some new Stage 2 core and menu objectives.




13 Core Objectives 17 Core Objectives
5 of 10 Menu Objectives + 3 of 6 Menu Objectives
18 total objectives 20 total objectives



What are the requirements?
17 Core Objectives – These are objectives that everyone who participates in Stage 2 must meet. Some of the core objectives have exclusions, but many do not.
3 of 6 Menu Objectives – You only have to report on 3 out of the 6 available menu objectives for Stage 2. You can choose objectives that make sense for your workflow or practice. Again, some of these objectives have exclusions.

The following is a list of the Stage 2 Meaningful Use 17 Core Objectives
1. Use computerized provider order entry (CPOE) for medication, laboratory and radiology orders
2. Generate and transmit permissible prescriptions electronically (eRx)
3. Record demographic information
4. Record and chart changes in vital signs
5. Record smoking status for patients 13 years old or older
6. Use clinical decision support to improve performance on high-priority health conditions
7. Provide patients the ability to view online, download and transmit their health information
8. Provide clinical summaries for patients for each office visit
9. Protect electronic health information created or maintained by Certified EHR Technology
10. Incorporate clinical lab-test results into Certified EHR Technology
11. Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, or outreach
12. Use clinically relevant information to identify patients who should receive reminders for preventive/follow-up care
13. Use certified EHR technology to identify patient-specific education resources
14. Perform medication reconciliation
15. Provide summary of care record for each transition of care or referral
16. Submit electronic data to immunization registries
17. Use secure electronic messaging to communicate with patients on relevant health information
In addition to the 17 core objectives, there are 6 Menu Objectives (and remember, you’ll only have to do 3 of the 6).
1. Submit electronic syndromic surveillance data to public health agencies ($-for the additional interface)
2. Record electronic notes in patient records
3. Imaging results accessible through CEHRT
4. Record patient family health history
5. Report cancer cases to a public health central cancer registry
6. Report specific cases to a specialized registry
Important Note: While there are exclusions provided for some of these menu objectives, you cannot select a menu objective and claim the exclusion if there are other menu objectives that you could report on instead.

Changes to Clinical Quality Measures
Beginning in 2014, the reporting of clinical quality measures (CQMs) will change for all providers.
You have the option of submitting three months of CQM data online through the CMS Registration & Attestation System. This will be the same website you go to for attestation now.
You also have the option to submit a full year of data electronically using the QRDA format to receive credit for the EHR Incentive Program and the Physician Quality Reporting System.
Please note that your attestation for the Medicare EHR Incentive Program is not complete until you submit clinical quality measure data, so your EHR incentive payment will be held until your electronic submission is processed.
If you are a provider using Medicaid, you must submit your clinical quality measurement data to your State Medicaid Agency.
How to Select CQM’s in 2014
Beginning in 2014, eligible professionals must select and report on 9 of a possible list of 64 approved CQMs for the EHR Incentive Programs.
There is also a new requirement in 2014 that the quality measures selected must cover at least 3 of the 6 available National Quality Strategy (NQS) domains, which represent the Department of Health and Human Services’ NQS priorities for health care quality improvement. The 6 domains are:
• Patient and Family Engagement
• Patient Safety
• Care Coordination
• Population and Public Health
• Efficient Use of Health Care Resources
• Clinical Processes/Effectiveness
In short there are a lot of changes this year in addition to ICD-10 implementation.

Stay tuned….

Sunrise Services, LLC


Submit Quality Data for 2013 PQRS-Medicare EHR Incentive Pilot by February 28, 2014

Are you an eligible professional who is participating or wishes to participate in the 2013 PQRS-Medicare EHR Incentive Pilot? You can now submit your 2013 quality data.

 If you would like to participate in the pilot you must submit 12 months of CQM data by February 28, 2014 at 11:59 pm ET.

To successfully participate in the pilot, you must do the following by February 28, 2014:

  1. Register for an IACS account (for EHR submission only)
  2. Indicate intent to report CQMs using pilot in EHR Registration & Attestation System
  3. Generate required reporting files
  4. Test data submission
  5. Submit quality data

If you cannot submit your CQM data for 12 months electronically through PQRS, you must return to the EHR Attestation System and deselect the electronic reporting option.  Please note: if you do not submit your 2013 quality data or deselect the electronic reporting option in the EHR Attestation System, you will not receive an EHR incentive payment.