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Three SAFER Guides Misconceptions Health Leaders Need to Know

Jun 1, 2023
Dennis Antishin
Maureen Gaffney

In 2022, the Centers for Medicare & Medicaid Services (“CMS”) announced guidelines with the goal of promoting the safer adoption, implementation and use of electronic health records (“EHR”). As part of this initiative, Medicare and Medicaid-eligible organizations must submit a self-attestation to the completion of the SAFER Guides, a nine-part safety assessment.

While self-attestation requires a simple “yes” or “no,” and the former of the two options is not yet a requirement, health care organizations are beginning the process for a second time. 

As with any new regulation in the ever-evolving health care industry, it is difficult to fully grasp the scope of everything the SAFER Guides attestation encapsulates. However, here are three misconceptions health care organizations typically have when navigating the SAFER Guides process.

Your EHR Vendor Cannot Complete the Assessment for Self-Attestation 

CMS requires each CCN/TIN to submit an attestation that the CCN/TIN completed a self-assessment. The EHR vendor cannot submit one on behalf of the CCN/TIN, nor can it perform a self-assessment for an organization since it is not the organization that has to attest.

CMS is looking for the attestation of each eligible provider’s EHR implementation and use of the recommended practices, including how they are satisfied from an operations and process/procedure perspective.

Your EHR vendor may provide evidence to support your assessment as it relates to certain functionality and configuration within the system, however, it cannot report on the operating effectiveness of a recommended practice within your environment.

The Self-Attestation Covers More Than Just Your EHR System

The SAFER recommended practices include, but are not limited to, assessments of the organization/provider’s policies, procedures, IT and clinical decision support governance, IT infrastructure, patient safety reporting and monitoring, on-going training and support. These practices are designed to provide a holistic review of the factors that impact the safe use of the EHR. 

The recommended practices are intended to provide a method to identify risks and safety gaps within the EHR and the ecosystem, supporting its safe use so as to avoid patient and clinician harm.

Recommended Practice Assessments Require More Than Just Checking a Box

To complete the assessment properly, your organization needs a multidisciplinary approach and executive involvement to identify opportunities for improvement and to break down barriers to remediate. The assessment process requires collaboration through remediation, which enriches dialogue and discipline to improve the safe use of the EHR.  

The SAFER Guides promote integration of EHR safety into the organization’s patient safety program and broadens communication about EHR safety to senior leadership and the governing board. 

CMS launched the SAFER Guides self-assessment to create a safer digital health environment for patients. While attesting “yes” is not yet a requirement, it’s important for health care organizations and patient safety leaders to fully understand the scope of these guides and how they play into their larger goals.

Is your organization ready to attest to the SAFER Guides?

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Dennis Antishin

Dennis Antishin is a Director in the Health Care Services Group providing digital health care services.

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