Meaningful Use Notice: Health Information Exchange

February 10, 2016

Dear Centricity™ Practice Solution and Centricity EMR Customers:

This is a Meaningful Use notice regarding the Health Information Exchange (formerly Summary of Care)

objective. Recent changes allow more flexibility for meeting this objective. GE healthcare is committed our

customer’s success - below is information about the rule change and guidance for both the 2016 reporting

period and 2015 attestation.

The below Summary of Rule Changes and the Additional Guidance – 2016 Reporting Period is informational for

all clients.

The Additional Guidance - Recommended Actions for 2015 Attestation is intended only for clients who have not

attested and who require additional guidance for meeting the thresholds for 2015 attestation. These

recommended actions do not apply to:

1) Customers who have already attested for 2015 reporting period 2) Customers who have not yet attested and who have met the thresholds for this measure for their 2015

reporting period and do not see a need to adjust their HIE performance numbers

Summary of Rule Changes:

Previous rules stipulate that eligible providers meet three measures for Summary of Care for Stage 2.

1) The EP who transitions or refers their patient to another setting of care or provider of care, provides a

Summary of Care record for more than 50 percent of transitions of care and referrals.

2) The EP who transitions or refers their patient to another setting of care or provider of care, provides a Summary of Care record for more than 10 percent of transitions and referrals either (a) electronically transmitted using CEHRT to a recipient or (b) where the recipient receives the Summary of Care record via exchange facilitated by an organization that is a NwHIN Exchange participant or in a manner that is consistent with the governance mechanism ONC establishes for the NwHIN.

3) Exchange a Summary of Care with a provider or third party who has different CEHRT (and different vendor) as the sending provider as part of the 10 percent threshold for measure #2, allowing the provider to meet the criteria for measure #3 without the CMS Designated Test EHR (for EPs the measure at §495.6(j)(14)(ii)(C)(1) with a recipient who has EHR technology from a different EHR technology developer than the sender's EHR technology certified to 45 CFR 170.314(b)(2). Or If unable to exchange Summary of Care documents with recipients using a different CEHRT in common practice, retain documentation on circumstances and attest “Yes” to meeting measure #3 if using a certified EHR that meets the standards required to send a CCDA (§ 170.202).

The Final Rule eliminates the first and third measures. It also stipulates that the second measure can be met by sending Summaries of Care electronically in a HIPAA compliant manner without leveraging the Direct Protocol or another certified transport method. GE Healthcare has determined from CMS that practices can count the send of a ToC via secure messaging using the Centricity Clinical Messenger (CCM) product.

Note that CMS indicates two possible exclusions from this measure:

1. Any EP who transfers a patient to another setting or refers a patient to another provider less than 100 times during the EHR reporting period.

2. Alternate Exclusion: Provider may claim exclusion for the Stage 2 measure that requires the electronic transmission of a summary of care document if, for an EHR reporting period in 2015, they were scheduled to demonstrate Stage 1, which does not have an equivalent measure.

We suggest that you review the recently released CMS measure specification for this measure: https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/2015EP_5HealthInformationExchangeObjective.pdf.

You should also review the CMS HIE Fact Sheet at https://www.cms.gov/Regulations-and-

Guidance/Legislation/EHRIncentivePrograms/Downloads/HIE_FactSheet.pdf.

Note that CMS states that “the referring provider must have reasonable certainty of receipt by the receiving provider to count the action toward the measure” – such reasonable certainty does not require confirmation for each summary sent but a reasonable expectation that summaries sent will be received. We suggest partnering with a clinic to confirm a successful transmission and documenting the event as proof of the expectation for successful future Summary of Care transmissions. Note also that CMS states that the “exchange must comply with the privacy and security protocols for ePHI under HIPAA” Finally, CMS states that: “This exchange may occur before, during or after the EHR reporting period but must

take place no earlier than the start of the same calendar year as the EHR reporting period and no later than the

date of attestation in order to count in the numerator.”

Additional Guidance for the 2016 Reporting Period Consistent with the increased flexibility under the final rule, GE Healthcare has made available an updated version of Centricity Clinical Messenger v7.0.2 that enables automated numerator reporting for the newly eligible secure messaging workflow for sending Transitions of Care. Because the 2016 reporting period is a full year, GE Healthcare recommends upgrading Centricity Clinical Messenger quickly to take advantage of the rule change and GE Healthcare’s corresponding product offering. We recognize that CMS permits other modes of electronic transmission but GE is focusing its automated reporting on its prior certified methods as well as CCM secure messaging. Additional Guidance - Recommended Actions for 2015 Attestation The following is guidance for clients who have not yet met the measure threshold for their 2015 attestation. Per the final rule provisions that now allow for additional electronic workflows for sending a ToC, GE Healthcare

has created a tool to identify all ToC transactions that occurred via both Direct and Secure Messaging within a

specified reporting period that are now eligible to count in the numerator for the Health Information Exchange

objective. Users can determine from the script’s output whether there are ToC transactions that are not

accounted for in CQR, and whether they contribute materially to an Eligible Professional’s performance for this

objective. Clients will need to reconcile the script output (total number of ToC transactions via Direct plus

Secure Messaging) with the current numerator score in CQR (total number of successful Direct transmissions)

and compute the resulting percentage using the CQR denominator to determine their measure percentage.

The denominator values are unaffected by this change.

Note: This script must be run on the Secure Messaging Server. To identify all ToCs sent during a specified

reporting period, messages from that period must exist on the server, e.g. messages cannot be purged. For

access to this tool, please contact GE Support.

If the threshold is still not met, the physician has not yet sent enough ToCs. Per CMS, clients can continue to

send ToCs up until attestation for transitions of care and referrals that occurred during the reporting

period. However, GE Healthcare only suggests sending or resending ToCs if there is good clinical reason to

do so.

If the threshold is met based on this review, customers have two options for attestation. First, a customer

can upgrade to Centricity Clinical Messenger v7.0.2 and work with Support to migrate the data to CQR. The

updated CQR data can be used for attestation.

If upgrading is not an option, then any results (historical or generated between now and attestation) must

be tracked manually and added by the customer to the data in the CQR dashboard. Customer should take

the proper steps to capture necessary documentation for use in potential audits. GE Healthcare

recommends the following for documenting ToC transactions outside of CQR:

o Option 1: Centricity Secure Messaging provides functionality called “CC to Chart” that enables users to append to chart a receipt of the transmission. Instructions on how to do this are included below.

o Option 2: Secure message actions are recorded in the Centricity Audit Log if the feature is enabled. By default, this feature is turned off. Instructions on how to enable this feature is included below. Option 3: Secure Messages are retrievable from the “Sent” messages folder in CCM. Note that most practices use the auto-delete feature. When enabled, the feature deletes all secure messages older than the configured amount of time whose default is 90 days. Users can turn off this feature if server space and performance permits. Users can also override the auto-delete feature at a message, user and profile level. Instructions on how to do this are included below.

Contact Information

If you need assistance or have questions, please contact Centricity Support Services by calling 1-888-436-8491

or via our e-service portal at https://engage.gehealthcare.com/. Please be assured that maintaining a high

level of quality and usability is our highest priority. If you have any questions, please contact us immediately per

the contact information above.

Instructions for How to CC to Chart:

1) Enable CC to Chart in Centricity Clinical Messenger

When creating a new secure message for a Summary of Care transmission, select the CC to Chart

checkbox highlighted below (Figure 1)

(Figure 1)

2) Validate Attachment to Chart

Navigate to the Documents tab to verify message receipt (Figure 2)

(Figure 2)

Instructions for How to Configure Auditing Events in Centricity:

1) Set up your auditing events

In Centricity select Go -> Setup -> Settings. From the left hand navigation select System ->

Auditing. Ensure the “Secure Message Sent” auditable event is displayed in the Log Audit

Events column (Figure 1)

(Figure 1)

Instructions for How to Override Secure Message Expirations:

1) Overriding auto-deletion at the Secure Message level

In the Messaging Center when creating a new secure message, click the Setting button, select the

“Expiration” tab and select your preference (Figure 1)

(Figure1)

2) Overriding auto-deletion at the Profile level In the Messaging Center, select the Profiles link in the Admin section from the left hand navigation, select

the “Profile Details” tab, select the “Message Settings” tab and select your preferences (Figure 2)

(Figure 2)

3) Overriding auto-deletion at the User level

In the Messaging Center, select the Users link in the Admin section from the left hand navigation,

select the “Message Settings” tab and select your preferences (Figure 3)

(Figure 3)