Legal Authenticator

Question

CMS requires a Legal Authenticator section and Meaningful Use is not requiring EHRs to provide that section as part of the C-CDA recent release.

How do you resolve this issue when the EHR will not add and that makes the C-CDA not valid for use with CMS

Answer 1

If you can setup a database query to the EHR then you could pull the data via SQL and then add it to the CDA "/ClinicalDocument/legalAuthenticator"

If you do not have access to the EHR then you could hard code values in a template of the legalAuthenticator. Maybe you could specify the values based on who is sending the CDA.

Comments

Yes the data is available either in the CCDA or the database but the question was really focused on - does coding the legalAuthenitcator still make it an official document if I am a third party vendor and not the EHR?

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According to the CMS document:
https://ecqi.healthit.gov/system/files/2018_CMS_QRDA_III_Eligible_Clinicians_and_EP_IG_v1.1_03122018_508.pdf

"the data is submitted through an intermediary such as a vendor, this authorization represents that the eligible clinicians and eligible professionals have given permission to release the report. MIPS and CPC+ all allow aggregation and submission by a vendor. If a vendor is used, then information about the vendor (e.g., TIN) is captured as the Legal Authenticator."

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Thank you for the information.  This is exactly what I was looking for.  Have a wonderful day.