http://www.meaningfulusemonitor.com | Ch 6 of Meaningful Use Monitor's e-Book: Commit to Meaningful Use Compliance Databases

1. Commit to Meaningful Use Compliance Databases
You do have options here. An emerging best practice relative to Meaningful Use Administration
is to have a dedicated repository of annual data to support attestation history, particularly for
large hospitals, health systems or large clinics.
In the early stages, when Administrator focus was on a single compliance year, a series of
spreadsheets supported by PDF reports in a shared drive on a network was a good start. As years
of history accumulate, this raw data storage becomes cluttered and needs an administrator who
knows the structures of where everything resides. The raw data also falls short in organizing
history and research across individual providers, or logical groups of providers. When the
administrator gets promoted or leaves the organization, a new individual begins to overlay their
own organizational scheme.
The current stage of sophistication is to use database technology that provides a single
comprehensive repository of documentation, attestation history, annual regulations, and even
audit experience. CEHRT technology is built to support clinical process, rather than program
compliance, and does not provide the structures for ongoing, annual repositories of history. The
Meaningful Use program as defined by Congress, and implemented by CMS, actually demands
that CEHRT will be upgraded regularly, and in the process could easily lose reporting
capabilities tied to early-stage attestations.
Follow the Design Patterns of Commercial Options
Providers have the option of creating, or purchasing databases dedicated to Meaningful Use
Administration. Whether evaluating one of the three of four commercial vendors, or designing
your own project, here are some key capabilities:
Maintain data by year and Stage for each EP or EH and CEHRT
Monitor your compliance by year and Stage for each EP or EH and CEHRT
Support efficient and effective Mock Audit for your EPs and EH
Provide financial projections for MU attestation payments (and penalties)
Support efficient attestation (i.e., Automated Batch, where supported by State or CMS)
Provide e-learning on Meaningful Use for staff new to Meaningful Use
Provide measure requirements by year/stage with clear delineation and links to Federal
Register
Have a MU expert available to assist in research and interpretation of regulations
Provide repository for answers to ongoing and annual MU questions (particularly where
answers support policy and system configuration issues)
Multi-user capabilities to support redundant knowledgeable staff
Secure, HIPAA-Compliant (preferably Cloud-based) storage by year and Stage

2. Provide all of this at a cost-effective price, reserving IT staff to achieving Meaningful
Use, rather than tracking administrative performance
Create your own CRAT for ARRA
OK, so we made up that acronym to represent Compliance Regulations Analytical Tool. ARRA
is complicated with hundreds of pages of three-column, fine print Federal Register prublications.
To keep up with ongoing developments, providers must scour the CMS FAQ site containing
thousands of entries, nearly 300 of which are pertinent to the EHR Incentive Program. Add in
the EHR Vendor Certification Final Rule and your head starts to spin. Once CMS Audit
Programs start generating findings and interpretations, we can expect further elaboration based
on those audit details.
So how providers should be collecting and organizing all this information, which represents sets
of regulations unique to each years’ attestation? Some people and some organizations are good at
mentally organizing all the information that will assure their successful attestation to Meaningful
Use – and ability to withstand a cynical CMS auditor who may appear over six years following
attestation. But most will find it useful to employ tools and techniques that institutionalize the
research and analysis of a couple key internal or external experts. Here are our top design
recommendations:
1. Deploy a database architecture - Databases provide structure that supports the
complexity of ARRA, with validation, transaction control, and a level of permanence
impossible in spreadsheets. Online databases facilitate real time communication /
collaboration across multiple teams (clinical, IT, Administration). And remember that
you’ll need to monitor meaningful use every year, individually for the foreseeable
future. Just imagine all the spreadsheets …
2. Cross-reference Measure and CQM content directly from the Federal Register(s) –
with references to specific page and column. Every day, our Knowledge Center team
answers questions from hospitals and clinics on Meaningful Use. Even with that level of
experience, knowing where to look, and in which Federal Register (there are actually four
of them so far relevant to Meaningful Use), saves time and gives our answers a solid
grounding in fact, supportable to even the most skeptical CFO or auditor. Give your
team this same edge.
3. Tie each Measure and CQM to new and updated CMS FAQs - as soon as they are
published. In fact, you’ll need to periodically review “old” FAQ's, and update your
knowledge center, since CMS sometimes updates historical items. And when CMS
Auditors hit the field, we expect further interpretations and elaborations for Meaningful
Use Measures.
4. Document your own standards and interpretations - for each Measure and
CQM. CMS actually states that providers will need to provider their own views in
FAQ’s on specific measures. As we progress through Meaningful Use, we find some
regulations leave room for a range of possible interpretations. Documenting your
organization’s formal interpretation will save confusion, provide consistency, and explain
to future auditors and reviewers the practicalities of why you took a given position.

3. 5. Link to PDF copies of your Certified EHR reports - on each Measure and
CQM. Once you have solid documentation of the unique set of requirements you’ve
configured from Core and selected Menu objectives, start running the reports from your
Certified EHR. Then use your CRAT to assemble all those reports under one
universally-accessible dashboard, complete with comments on progress or impediments
your Meaningful Use Analyst needs to track and share.
6. Link to workflows and policies - associated with each individual Measure and
CQM. Meaningful Use will be based as much on your policies and procedures, as on
your technology. Having all your policies and procedures in the same CRAT with the
time-specific regulations and interpretations will help your process team and clinical staff
be in compliance, and defend your position.
7. Enforce Retention Policies - (explicit retention requirement of six years). You don’t
need to store interim CEHRT reports for the long term. But once your organization (or
individual EP) hits Meaningful Use over an appropriate reporting period, you’ll want a
permanent snapshot of the state of your CEHRT’s content for each Measure and
CQM. We also think it important to tie each report to the specific Regulations, your
interpretations, and your processes that exist during that reporting period (based on
Federal Register, FAQ and Audit Report data).
8. Deploy online, self-directed e-Learning material - configured to the needs of different
clinical, executive and operational teams. In-person training session might get to most of
your team, but given the nuances and complexity of Meaningful Use, some members will
benefit from the ability to review the content multiple times, and even to use a quiz to
reflect upon the material and solidify their knowledge. Of course, online e-learning also
gives people the ability to study at their own time and pace. And most Learning
Management Systems give you the ability to track education progress at whatever level
you deem appropriate.
9. Staff a Knowledge Center – Dedicate at least one primary contact, deeply
knowledgeable in all of meaningful use as the central resource for answering questions,
researching the regulations, and resolving ambiguities in the regulations, or your
EHR. It’s probably a good idea to have a fallback person in the event your primary
contact becomes unavailable. Knowledge Center resources are a great supplement to
your on-line e-Learning material as well.
10. Automate the Attestation Processes– particularly for EP’s attesting involves a lot of
individual transactions, which require a lot of effort to track and execute. CMS has
started to provide a complex interface for attesting batches of EP’s, which can save tons
of time and reduce errors. But the details of their specification are beyond the capabilities
of most non-programmers. Part of the Attestation Process is automating the analysis of
compliance readiness across large physician populations. We have found that simply
figuring out which EP’s are ready to attest is more time consuming than the attestation
itself. (Remember last time you did your personal income tax return? Assembling
documentation to decide what to report, and how is as much work as filling out the
forms.)
Becoming compliant with complex regulations in an organization the size of even a small
hospital, or medium-sized ambulatory group requires formal capabilities in research, analysis,

4. communication and measurement. Using a well-structured toolset will enhance these disciplines
and save time in nearly every case.
Commercially Available Meaningful Use Administrative Databases
We used the acronym “CRAT”, because the market does not yet recognize a category of
administrative tools that support Meaningful Use. It is hard even to construct a Google search
that will return a list of competitors. Our firm markets a comprehensive product that forms the
outline you’ve just reviewed. While we think our Meaningful Use Monitor is the premier of
these products, our clients often evaluate a couple others on the way to selecting Meaningful Use
Monitor. Here’s a quick overview.
MUM or Meaningful Use Monitor is a cloud-based product by C3 Partners, LLC. It
supports ambulatory and inpatient domains, and is supported by Meaningful Use Help
Desk, an educational portal, and mock audits associated with each subscription. The URL
is MeaningfulUseMonitor.com, and its Help Desk site is MeaningfulUse.Guru.
SA-Ignite markets a product called MU Assistant, originally deployed and used by a
number of Regional Extension Centers (RECs) for small physician practices, and is
oriented toward Eligible Professionals. The URL is SAignite.com.
Iatric has a product based on its strong Meditech relationships, primarily in hospitals.
Their Meaningful Use Manager is typically installed on-site, and has the benefit of
reproducing Meaningful Use reporting that is typically weak in Meditech installations.
We’ve seen a couple other products enter and leave the market, but these three have sufficient
user base to validate a market need, and to provide long-term sustained capabilities.