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Mirth Certification and Meaningful Use

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  • #16
    I'm not a lawyer either, but I used to work at an HIE where (among other things) we would facilitate MU attestation/certification for a variety of clients. Of course we also had legal council that helped to guide us on the right track, but never once did we have to certify the integration engine the client used (whether it was Mirth Connect, Cerner Open Engine, Cloverleaf, etc.). At least, not to my knowledge.
    Step 1: JAVA CACHE...DID YOU CLEAR ...wait, ding dong the witch is dead?

    Nicholas Rupley
    Work: 949-237-6069
    Always include what Mirth Connect version you're working with. Also include (if applicable) the code you're using and full stacktraces for errors (use CODE tags). Posting your entire channel is helpful as well; make sure to scrub any PHI/passwords first.


    - How do I foo?
    - You just bar.

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    • #17
      OK, well once again, I am back to my original predicament. On one hand, I have my lawyer telling me that I must certify my interface engine.

      On the other hand, I have others saying no I don't. Excuse me for about 10 minutes while I tear my hair out.

      Narupley, were you just passing the information through or were you making any changes?

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      • #18
        Originally posted by wit-man View Post
        OK, well once again, I am back to my original predicament. On one hand, I have my lawyer telling me that I must certify my interface engine.

        On the other hand, I have others saying no I don't. Excuse me for about 10 minutes while I tear my hair out.

        Narupley, were you just passing the information through or were you making any changes?
        In most cases we were making changes to the data being passed through the engine. In some cases the client also used their own integration engine, and likely made plenty more changes then too.
        Step 1: JAVA CACHE...DID YOU CLEAR ...wait, ding dong the witch is dead?

        Nicholas Rupley
        Work: 949-237-6069
        Always include what Mirth Connect version you're working with. Also include (if applicable) the code you're using and full stacktraces for errors (use CODE tags). Posting your entire channel is helpful as well; make sure to scrub any PHI/passwords first.


        - How do I foo?
        - You just bar.

        Comment


        • #19
          The rule that is being cited by your legal council would be of great insight to everyone I think.

          I review the product that you referenced in your link and it appears to be a canned solution that provides very specific results and that would appear to be the interest in MU Certification then just the usage of the product or the manipulation of a message or sending out a message.

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          • #20
            I am getting more information that seems to support everyone's claim that it doesn't have to be certified. Might be time to have another chat with our attorney. I will post anything I find out. Thanks.

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            • #21
              Ok, have a look here:

              https://questions.cms.gov/faq.php?id=5005&faqId=3211

              Direct from CMS. Looks like I do indeed have to have a certified interface engine.

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              • #22
                So your usage of Mirth is related to CQM specifically?

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                • #23
                  We use it to submit syndromic surveillance data, immunization data, will be using it to deliver CCDs, and transmit lab tests to providers.

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                  • #24
                    The response from CMS is related to the usage of a non-certified product to meet Clinical Quality Measures reporting related to Meaningful use. As I read it. The issue would be that you manipulated the data associated with CQM reporting with a product that is not MU Certified with a Non-Certified solution. This would be an issue. But that is not what you are doing from what I understand. CQM is a very specific Chapter in the Certification process and has very specific rules.

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                    • #25
                      The question in the link that I provided was this:

                      "[EHR Incentive Programs] If a provider purchases a certified Complete Electronic Health Record (EHR) or has a combination of certified EHR Modules that collectively satisfy the definition of certified EHR technology, but opts to use a different, uncertified EHR technology to meet certain meaningful use core or menu set objectives and measures, will that provider be able to successfully demonstrate meaningful use under the Medicare and Medicaid EHR Incentive Programs?"

                      The individual measures that we are trying to meet are the ones listed in my previous post. We aren't using it for CQMs.

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                      • #26
                        "use core or menu set objectives and measures" This is a reference to CQM specifically. I am not sure this answer relates to your usage. Not sure this relates to your usage.

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                        • #27
                          It is also a reference to the different objectives we must do for both EP and EH requirements.

                          EP:

                          http://www.cms.gov/Regulations-and-G...ntents_EPs.pdf

                          EH:

                          http://www.cms.gov/Regulations-and-G...itals_CAHs.pdf

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                          • #28
                            But the EHR would still be able to do each of those things on its own as it is certified. Your doing them would have nothing to do with the EHR ability to that would it?

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                            • #29
                              That's correct but if you read the answer to the FAQ I posted asking if someone who had a complete certified EHR but uses an uncertified EHR technology to meet core or menu objectives or measures, it states:

                              "No, the provider would not be able to successfully demonstrate meaningful use....A provider using uncertified EHR technology to meet one or more of the core or menu set measures would not be using the capabilities and standards that were certified to accomplish each objective."

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                              • #30
                                More info on certified technology for MU

                                https://questions.cms.gov/faq.php?id=5005&faqId=3211

                                From my interpretation and referenced CMS FAQ (as well as wit-man) it suggests MIRTH would require certification if it is used to meet any of the objectives outside of what the vendor certified. The FAQ does reference 10589 with some exceptions unfortunately I do not find any information on FAQ 10589. A couple years ago I found specific reference to using a uncertified integration engine and it specifically stated it would not qualify. I can not find that reference again but still looking.
                                Last edited by Slingshot; 07-26-2013, 09:28 AM.
                                HL8 Certified

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