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CCHIT Certified® Ambulatory EHR Test Step FAQs Question
Why we are keeping the record for the Joe Gardner that was It does not matter which record you keep as long as the jurors just created when there was already data for Joe Smith. Our can see that your system can electronically merge the two files process is to delete one record and while deleting it asks you if and the end result is a record for a patient with the name of you would like to merge the record. Does it truly matter which Joe Gardner with all the correct history on it. one we delete/merge as long as the data for both exists in the resulting record? Regarding item 1.18 in the test script where it describes The criterion associated with your question from Step 1.18 capturing height, weight and temperature in English or metric units: is this step requiring that a single field must be able to “AM 08.14 The system shal provide the ability to capture and accept either English or metric units? i.e., that if the EMR user display temperature, weight and height in both types in a value for weight in pounds and then switches to metric that I would need to automatically convert the number to kilograms. You would need to demonstrate that the user has the option to enter the temp, weight and height in either metric or English units and be able to have the system convert the values if the user wishes to change to the alternative measure. Please explain what is meant by „illustrate pain level‟. For Step 1.20, the requirement is to capture a numeric pain level (in this step they are asking you to record zero) in a discrete data field. You would need to demonstrate this ability to be compliant with this step. Do we have to actually scan the consent in during the You must scan the consent form in Step 1.32. However, for inspection, or can we have it pre-scanned and just show the any subsequent steps that require scanning, you can pre-scan jurors how we would attach it to the patient‟s chart? them and just show jurors the attachment of the image to the Is it ok to re-enter the medication name in order to access the The criterion associated with this step is not specific to how the general prescribing information for Albuterol? functionality of the link to the external source should work, therefore, as long as the provider has means to access the information, even though it requires re-entry of the medication name, should be sufficient. You would need to demonstrate that you can retrieve the information for Albuterol through the external site for the prescribing information. CCHIT Certified® Ambulatory EHR Test Step FAQs Question
Is it ok to re-enter the medication name in order to access the The criterion associated with this step is not specific to how the patient medication information for Albuterol? functionality of the link to the external source should work, therefore, as long as the provider has means to access the information, even though it requires re-entry of the medication name, should be sufficient. You would need to demonstrate that you can retrieve the information for Albuterol through the external site for the patient information. Is this change provider-specific or is it a global change to all Either is permitted, though if you are using provider-specific changes, it is recommended that you change al users‟ configurable text at Step 1.48 who write prescriptions for the remainder of the text script as our jurors will expect all future prescriptions in all scenarios to have this text. Does a “site-specific” care plan refer to a specific location? The term “site-specific” actually doesn‟t refer to a location. It can be better understood if you think of it as “patient-specific”. In this step, the jurors will look to see that the provider can add a patient-specific note to the patient‟s plan of care. What is the definition of „credentials‟? Is it the designation of Credentials in this step would refer to the clinical licensure of the individual, like „physician‟ or „nurse‟, or is it referring to their the individual, such as MD, DO, RN, etc. clinical licensure? We are currently configured to prevent the user from getting to 1. Upon seeking access, the provider (without the visit information/PHI, but they would have access to necessary access privilege) must be notified that it is demographics information. Do you consider restricted access restricted from accessing the patient record including to the chart as being any information including patient name/address/contacts, or is limiting them to not see any 2. However, the provider must be allowed to request information from patient encounters as we have done access to the patient information in the case of an 3. The provider must be prompted to document its 4. Upon documenting the reason (i.e. emergency care), access must be provided (i.e. break-the-glass). CCHIT Certified® Ambulatory EHR Test Step FAQs Question
Can we store the diagnosis in our database, or does it need to The jurors will be looking for a coded diagnosis list. The code associated with the problem (pneumonia) should be visible in the GUI, not the database. CCHIT is not specific where in the GUI the code associated with the problem should be stored. Is this intended to be a global or a patient-specific change? Step 2.09 is to show that you can make a patient-specific change for this high risk patient, Jennifer Thompson. This is not a global change. Does the mammogram need to actually be ordered? There is no requirement that the mammogram be ordered, but if your system requires the mammogram to be ordered so that you can modify the mammogram instructions, you may place that order. Should these tasks be sent to all users with the role of In Step 2.19, we are testing that a receptionist is sent „Receptionist‟ or to a specific user called „Receptionist‟? notifications regarding the patient. This could be role based so that all receptionists receive the message but that is not required. During the inspection, the jurors will only expect to see that the user you have set up as the Receptionist for your test receives these tasks. Does the restriction have to be at the level of the user role Only physician users should be able to see the confidential (physician)? Is it acceptable if the ability to view confidential information. This will be tested in a later step when a nurse tries to access the information and is not allowed or cannot see it. If you have this “confidential” area or tab of the chart set up ahead of time by your system Administrator so that only physician users can access, enter data and see it, that should allow you to carry out this step properly and meet the requirements of denying access to other users in later steps. Is it ok if other patients other than those listed in the Expected For Step 2.23, the outstanding HgbA1c orders that display must include patients Jennifer Thompson and Joe Gardner. If other patients also appear in the list this is acceptable. CCHIT Certified® Ambulatory EHR Test Step FAQs Question
What changes have been made since 2008 testing? In addition to test name, value and units as required in 2008 testing, all lab results will now require an indication if the result What changes have been made since 2008 testing? This scenario will require structured entries for the Demographics, Medication, and Allergies sections. You must use RxNORM or NDC for coded medications, and RxNORM and UNII for coded Allergies (medications and food/substance). Applicants can select which standard HITSP C32 v2.3 or HITSP C32 v2.5 they wish to use when creating the CCD. Can you review the steps that are taken by CCHIT to validate Your file will be validated using Laika for errors and warnings. However, any errors and warnings generated by Laika are
always verified manually. The file will also be visually
validated for content. A document that passes the online NIST
validator will not necessarily pass CCHIT validation as we still
need to verify that the content is present and accurate in the
document.
CCHIT Certified® Ambulatory EHR Test Step FAQs Question
Can we use an automated update for this step? No, this is not an automated update. A user must log in to make these changes. In Step 4.07 the provider should be able to post or store updated reference information that they have received on some prevention or disease management topic. You should be able to either incorporate the material into your EHR or create a link in your EHR to launch the material on the web. Then based on the content of this updated reference material, the provider should be able to adjust the prevention or disease management guidelines for all of his patients. For example, he could update the guidelines to require all male patients to start having PSA tests at age 40 (instead of 50 for example). You should demonstrate how to change the prevention/disease management guidelines that trigger reminders for the jurors based on the updated reference information you loaded earlier. You don‟t have to use the PSA example; you could use something else if you wish. Our system uses the term „patient refused‟. Is this ok? Using the words “patient refused” instead of “patient preference” still meets the intent of the criterion to document the reason for the variation from the rule-based clinical message as long as it is captured as discrete data. Can we show the jurors the patient‟s past surgical history to For Step 4.11, the jurors will expect to see the ICD-9 code linked to the diagnosis description in a central problem list, so all the diagnoses from prior visits should be listed in one location. Additionally, the jurors will expect to see a similar grouping of information for the resolved diagnoses of appendicitis, cholecystitis and cataract. Viewing the patient‟s past surgical history would not meet the expected results of this test step. Does it matter if the results are sorted in ascending or Step 4.16 is not specific to ascending or descending. The Expected Result is simply to sort by test date, so you can demonstrate compliance by showing either. CCHIT Certified® Ambulatory EHR Test Step FAQs Question
Can the care plan entry be entered as free text? This change should capture a date for the provider when the next lipid testing is due. It should be a recurring note or reminder that shows the due date at each consecutive visit (ongoing care plan). For example: it‟s in the area of the record that always displays to the provider for patient wellness reminders. The method you use to accomplish this is determined by you. Is it acceptable for the applicant to enter Aleve as a Either method is acceptable. We simply need to see that the prescription, or should it be entered simply as a medication the OTC medications can be added to the patient‟s medication list. Is it acceptable for the applicant to enter Tums as a Either method is acceptable. We simply need to see that the prescription, or should it be entered simply as a medication the OTC medications can be added to the patient‟s medication list. Where do we get the x-ray report to link to the original x-ray You will need to create the x-ray report yourself prior to the inspection, making sure it contains the verbiage „Knee x-rays show severe arthritis with total loss of joint space on the left.‟ Then in Step 4.43 you will view these results and then link them to the original x-ray order. Can we manually attach the report to the x-ray order, or does The system doesn‟t have to have an “auto-link” function set up so that the report matches automatically to the order when it is brought in to the EHR. It can be a completely manual process of opening the document, matching it manually to the right patient, and then manually uploading it and manually linking it to the correct order. CCHIT Certified® Ambulatory EHR Test Step FAQs Question
Do we need to create our own x-ray image? You will need to create an x-ray image for this patient prior to the inspection; this can be done via a link to a URL or via an actual image file. Then, in Step 4.45, you must demonstrate that you can either incorporate the URL into Theodore Smith‟s record or incorporate the image from the .jpg file into his record. You must then be able to show that you can view the image from within Theodore‟s chart (either by clicking the link or opening the image). We want to make sure linking both the x-ray image and x-ray Step 4.46 requires that the image and some “non-numerical” report to an encounter (and subsequently the same diagnosis) result be linked together. Simply filing them both on the same will satisfy this requirement because the two documents are patient encounter record does not meet the intent of this step. not actually direct linked to each other…they are linked through You could demonstrate this step by placing a link to the image file within the x-ray report body or vice versa. The intent is a shortcut for the provider to go back and forth between the report and the image. Is it permissible to have a doctor manually indicate that he is Since the criterion says “the system shal ….” and the identity the one who wrote the addendum (using a drop-down menu) is included in the same criterion statement as the date and and when he saves his addendum have the system time which have explicitly been called out to be system automatically save and display the date/time of his changes? generated and recorded, they should all be system generated and recorded, including the identity of the person altering the note. The expiration date for Celestone is June 2010, which means Please change the expiration date for Celestone to be 1 month that it is technically expired. Should we really set this up to after your inspection date. For example, if your inspection date is on December 12, 2010, the expiration date you would use We are directly certified with SureScripts for ePrescribing. Do No, this step is only for those using a 3rd party ePrescribing CCHIT Certified® Ambulatory EHR Test Step FAQs Question
Within the CCHIT Test Pharmacy, will there be a test patient Both the SureScripts staging environment and RxHub‟s for Theodore Smith with Medication History data? Or is this database contain Theodore Smith and the medications should something that we are expected to populate in the PBM data? match what is in the Expected Results for Step 4.58. It unnecessary for you to pull the medication history information Also, do you want us to pull the PBM medication history data into your application. Simply show the queried results to the into our EHR? All of the drugs that are queried to the PBM (with the exception of Warfarin) are already added in from Appendix C. For eRx will we actually need to configure and send to Testing this year will require the transmission of an electronic SureScripts this year or will we be faxing the prescriptions? prescription in Step 4.65. You will need to demonstrate compliance with this step in addition to providing your SureScripts documentation this year. You will still need to fax a prescription to us twice in Steps 1.45 and 1.46, and you can do this directly from your system or through SureScripts if they will allow the re-fax. In these steps CCHIT is acting like a non-participating/non-electronic pharmacy since there are still about 40% of small community pharmacies that do not accept electronic prescriptions in the U.S. Please clarify what is meant by the term „filtering‟. Does it Filtering for this step does not have the same meaning as Sorting. In this step, “filtering” means being able to select from a range and only have those encounters appear. In other words, certain encounters would be excluded based on the filter. Our system has the ability to create a list of patients to be The intent of Step 4.73 is that you are able to exclude excluded from populating reports. Is that sufficient? individual patients from reporting functions based on their preference or the provider‟s wishes. Only having the ability to create a list of patients to be excluded from populating the report would not be sufficient. Having a discrete data field associated with each patient medical record is what is required for this step. CCHIT Certified® Ambulatory EHR Test Step FAQs Question
In our system, we track the patient name as part of his visit This only needs to be a list of encounter dates for Joe, you information. Through the test scripts, the visit information from don‟t have to actually show the reports/encounter records so past years was originally input from Appendix A under the you could display Joe‟s ID information at the top and just a name "Joe Smith". When we merge these patients in Step simple list of visit dates and that would suffice. 1.04, the old records still maintain the name "Joe Smith". When we print this report in 4.75, it displays the new visits from the test script as "Joe Gardner" and the old visits on the name “Joe Smith". The test script is unclear in saying that it wants "Joe Gardner's" visits. Can we cut and paste information from the system-generated Cutting and pasting into another document does not meet the report into a Word document to demonstrate compliance with intent of “automatic generation”. However, if the report output is in the form of a letter that can then be printed, that would be sufficient. Can we login as the administrative user to show this step? Logging in as an administrative user to perform this step is acceptable. The administrative configurable rules table would not constitute a coding change and is allowable. What is the definition of the formal health record? “Formal Health Record” is a term taken from the HIPAA legislation and requires that each provider site define what pieces and parts of the patient record will make up the Formal Health Record at their site. How you define the formal health record is at your discretion. Our system does not allow us to open up two EHR sessions These steps require you to be logged on to the same patient side-by-side. How will we be able to demonstrate this step? record at the same time as two different users. To demonstrate these steps you may deploy Remote Desktop, PC Anywhere, open two sessions side by side, have multiple users logged on to the GoToMeeting Session and CCHIT can switch presenters during the demonstration, etc. CCHIT is not prescriptive about how these steps can be demonstrated as long as the jurors can see the Expected Results clearly. CCHIT Certified® Ambulatory EHR Test Step FAQs Question
Must we create the reports during the inspection, or can we do The report parameters can be created ahead of time and saved. The jurors will then need to see the report compiled during the inspection. Jurors have the right to request to see the parameters that were used to develop the report. We use DrFirst for our medication table. What do we need to For Step ADM.05 the jurors will be looking for you to display a do in order to demonstrate this step? Is it ok to login as a table of drugs and show that each drug has a unique identifier. CCHIT is not specific as to which coding system is used; it could be internal to your system, NDC, etc. You should obtain a copy of the drug table or subset of the table from DrFirst to display so the jurors can see what the master table looks like and just show them that the medications list contains a unique identifier number or code for each medication. You can log in as an administrative user to perform this step if necessary. Is the intent of this step to show the jurors that Dr. O‟Brien is The intent of Step ADM.08 is for you to show the jurors how a provider role can be specified for a particular patient. Dr. O‟Brien should not be given the global role of PCP as this should be a patient-specific designation. The jurors will need to see this assignment on the day of your inspection, so make sure you do not list Dr. O‟Brien as the PCP prior to that. How is Step ADM.09 different from ADM.10? Steps ADM.09 and ADM.10 are very similar, except in ADM.10 we also need to see how you update the reference materials. ADM.09 could be demonstrated by changing a disease management alert. CCHIT Certified® Ambulatory EHR Test Step FAQs Question
Can you give us some examples of what we could do to Associated reference material could mean patient educational material in Step ADM.10. For example, if you change the parameter for a disease management criterion, you would want to assure that the associated reference materials (e.g. patient educational material) is also updated. Step ADM.10 could be demonstrated by adding new reference materials (files) or links to reference materials and then developing a new disease management reminder based on those new materials. Embedding a link is one possible way to demonstrate compliance with this step, but it is not the only way. Do we have to have the ability to capture all of the examples At a minimum, your system must have the capability to store a provider‟s state medical license, DEA and NPI numbers. Do we need to actually change the severity warnings in this You do not need to save a change to the level of interaction warnings for this step, just show the jurors where and how you would make a change to the level of interaction warnings that would appear to providers. This is intended to be a global change, not specific to any medication. We are an ASP model EHR, and we control the immunization The criterion for this step says “at the user/administrator level”. database. We update the database which is then provided to However, CCHIT understands that the Administrator in this all customers. ADM.14 makes sense for a client server step is at the vendor level due to the ASP model. ASP application in which the application is controlled by the applicants may login as the System Administrator to execute customer at their site. In our case, we research what is needed for the immunization registries and update the database. For ADM.14, it indicates the user at the clinic has to be able to add to the database or could it be us as System Administrators adding it to the system‟s database? CCHIT Certified® Ambulatory EHR Test Step FAQs Question
Is it ok if we just sort the list by the problems entered by the The intent is that for different specialties, the problem list would display differently. For example, the cardiac problems could be on the top of the problem list when a Cardiologist logs in, but if an Orthopedist logs in, s/he could see the Orthopedic problems at the top instead of the cardiac-related ones. This is only an example; there may be other ways of arranging or displaying the diagnoses by specialty. This does not have to be an automated process based on the login. The provider may initiate the reorganization of the list by taking some action in the system. Can we manually populate the CV/Risk Factor Panel? Yes, you may manually populate the CV/Risk Factor Panel in order to demonstrate compliance with this step. Is it permissible to save the ECG file outside of the EHR (e.g. No, this not permissible. If the image cannot be emailed from to the desktop), open an external email client, and then attach within the system, you must instead transmit the image via fax the file to an email for the transmission? from within the EHR or via an FTP server.

Source: https://www.cchit.org/documents/18/158304/2011+Ambulatory+Test+Step+FAQs+CCHIT+Certified.pdf