CMS Issues More Answers to EHR Incentive Program Questions

Question: If a provider utilizes a health information organization that participates with the eHealth Exchange but is not connected to public health entities in the provider’s state, does the provider still need to connect to those entities for purposes of participating in the Medicare and Medicaid EHR Incentive Program?

Answer FAQ #8906: Yes, to meet the requirements for meaningful use, the provider must connect to the appropriate public health entities in his or her state, even if the provider has connected to an eHealth Exchange participant for other reasons. This can be accomplished by expanding the eHealth Exchange participant connections to include public health agencies, or through direct connections from the provider to the public health agency, or through a different third-party interface. Read the full answer here.

Question: How does a provider attest to a meaningful use objective (e.g., the “transitions of care,” “view/download patient data,” and public health objectives) where the provider electronically transmits data using technical capabilities provided by a HIE?

Answer FAQ #8908: Several meaningful use objectives require eligible professionals, eligible hospitals, and Critical Access Hospitals (CAH) to conduct electronic transmissions. In general, eligible professionals, eligible hospitals, and CAHs may use an HIE to meet a particular meaningful use objective if the HIE has been certified to support that objective. If an eligible professional, eligible hospital, or CAH uses an HIE to satisfy a particular meaningful use objective, the provider will need to include the HIE’s certification number, as a certified Electronic Health Records (EHR) Module, in their attestation. Read the full answer here.

Question: If an EP or hospital attesting to meaningful use in the EHR Incentive Program submits a successful test to the immunization registry in year 1 of Stage 1 and engages with the immunization registry in year 2, but does not achieve ongoing submission of data to the immunization registry during their reporting period in year 1 or year 2, should they attest to the measure or the exclusion?

Answer FAQ #8910: The Stage 1 MU measure requires the EP or hospital to perform at least one test of certified EHR technology’s capacity to submit electronic data to immunization registries, and follow-up submission if that test is successful. An EP or hospital that can demonstrate engagement with the immunization registry during year 2 would attest to meeting the measure even if that engagement was not in the form of another test. Read the full answer here.

Question: Can a state capture electronic Clinical Quality Measures, or eCQMs, for the Medicaid EHR Incentive Program through a Health Information Exchange (HIE)?

Answer FAQ #8902: Yes, a state can capture clinical quality data for eCQMs using an HIE, and states should consider the health data landscape of their state when designing a system to collect eCQMs for the Medicaid EHR Incentive Program.  Utilizing an HIE can allow the state to collect more sophisticated patient-level data, to encourage provider adoption, and to facilitate alignment between various programs, such as those authorized under the HITECH Act, Accountable Care Organizations, and Medical Homes. Read the full answer here.

Question: Can a public health agency use a HIE to interface with providers who are submitting public health data to meet the public health objectives of meaningful use (such as submitting information to an immunization registry, reporting lab results to a public health agency or reporting syndromic surveillance information)?

Answer FAQ#8904: There are a variety of methods for the exchange of public health information, and CMS does not limit or define the receiving capabilities of public health entities. Among other requirements as specified in the regulations, a provider must submit data for the public health objectives of meaningful use  Read the full answer here.

See more CMS New FAQs published on next pages.