Meaningful Use and Public Health Reporting Frequently Asked Questions
1. FAQ-Sending a Meaningful Use Test
FAQ 1.a
In a setting where there are several EPs from an affiliated organization, implementing the same version of a certified EHR, does sending one test to the immunization registry demonstrate meaningful use for all affiliated EPs?
Answer 1.a
Specifically for the PH [Public Health] measures, we do allow for one test from a group practice to suffice for all the EPs in that practice (see preamble to final rule, page 44365). However, this MU objective also requires follow-up electronic submission of IR data if the test was successful. That part is still required at the EP-level.
-Kahn, Jessica (CMS/CMSO) email.
2. FAQ-Meaningful Use & Reporting Period
FAQ 2.a
Under the Medicaid Electronic Health Record (EHR) Incentive Program, if a provider adopts, implements or upgrades (AIU) certified
EHR technology in their first year, the provider will not have to demonstrate meaningful use in order to receive payment; in the
second year they will have to demonstrate MU for a 90 day period only. Whereas a provider that is already a meaningful user would
have to demonstrate for a 90 day period the first year and subsequent years they would have to demonstrate it for the full year.
Is this correct? http://www.cms.gov/EHRIncentivePrograms
.
Answer 2.a
This is correct.
FAQ 2.b
Can an eligible professional (EP) implement an electronic health record
(EHR) system and satisfy meaningful use requirements at any time within
the calendar year for the Medicare and Medicaid EHR Incentive Program?
Answer 2.b
For a Medicare EP's first payment year, the EHR reporting period is a
continuous 90-day period within a calendar year, so an EP must satisfy
the meaningful use requirements for 90 consecutive days within their first
year of participating in the program to qualify for an EHR incentive
payment. In subsequent years, the EHR reporting period for EPs will be
the entire calendar year. With regard to the Medicaid EHR Incentive
program, EPs must have adopted, implemented, upgraded, or
meaningfully used certified EHR technology during the first calendar
year. If the Medicaid EP adopts, implements or upgrades in the first year
of payment, and demonstrates meaningful use in the second year of
payment, then the EHR reporting period in the second year is a
continuous 90-day period within the calendar year; subsequent to that, the
EHR reporting period is then the entire calendar year.
http://www.cms.gov/EHRIncentivePrograms
FAQ 2.c
If my organization performed a meaningful use test with a public health agency prior to my reporting period,
do I need to send another test message within the reporting period I am going to attest under? Do I need another
letter of confirmation from the State of Michigan?
Answer 2.c
According to the CMS Final Rule Paragraph Citation 75 FR 44367, “The testing could occur prior to the beginning
of the EHR reporting period, but must occur prior to the end of the EHR reporting period”. Therefore, if your
organization had previously tested with one of the public health agencies to fulfill Stage 1 Meaningful Use and
your organization pushed your reporting period to a later date, then that one test and one letter of confirmation
will fulfill your testing requirement.
3. FAQ-Certified Technology
FAQ 3.a
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?
Answer 3.a
No, the provider would not be able to successfully demonstrate
meaningful use. To successfully demonstrate meaningful use, a provider
must do three things:
- Have certified EHR technology capable of demonstrating
meaningful use, either through a complete certified EHR or a
combination of certified EHR modules;
- Meet the measures or exclusions for 20 Meaningful Use
objectives (19 objectives for eligible hospitals and Critical Access
Hospitals (CAHs)); and
- Meet those measures using the capabilities and standards that
were certified to accomplish each objective.
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. Please note
that this does not apply to the use of uncertified EHR technology and/or
paper-based records for purposes of reporting on certain meaningful use
measures (i.e., measures other than clinical quality measures), which is
addressed in FAQ #10589.
http://www.cms.gov/EHRIncentivePrograms
4. FAQ-Exclusion & Public Health Reporting
FAQ 4.a
Does my practice qualify for exclusion to the meaningful use objective of capability to submit electronic data to immunization information systems?
Answer 4.a
MDCH has determined MCIR (Michigan Care Immunization Registry) has the capacity to receive immunization data in accordance with the established meaningful use vocabulary and content exchange standards. Therefore, all eligible professionals and hospitals administering immunizations in Michigan do not qualify for exclusion to the meaningful use objective of capability to submit electronic data to immunization information systems.
FAQ 4.b
Do eligible hospitals qualify for exclusion to the meaningful use objective of capability to submit electronic lab results to public health agencies?
Answer 4.b
MDCH has determined MDSS (Michigan Disease Surveillance System) has the capacity to receive electronic lab results in accordance with the established meaningful use vocabulary and content exchange standards. Therefore, eligible hospitals can not attest exclusion for the reason the state does not have the capability to accept electronic lab results.
FAQ 4.c
Does my practice qualify for exclusion to the meaningful use objective of capability to submit electronic data to syndromic surveillance information systems?
Answer 4.c
MDCH has determined MSSS (Michigan Syndromic Surveillance System) has the capacity to receive syndromic data in accordance with the established meaningful use vocabulary and content exchange standards for eligible hospital emergency departments only. Therefore, eligible professionals that are required to report syndromic data according to meaningful use objectives do qualify for exclusion to the meaningful use objective due to the state not having the capacity to accept syndromic data electronically.
Please note: MSSS is currently working towards expanding its capacity to accept syndromic data from Eligible Providers (EPs) for future Meaningful Use testing in 2012. Once more information becomes available regarding the timeline on MSSS accepting EP's syndromic data, we will post the information at: http://www.michiganhealthit.org/meaningful_use/publichealth.aspx
FAQ 4.d
Does MDCH provide a letter of exemption to a provider that is going to
attest exclusion for one of the public health reporting options?
Answer 4.d
No, MDCH does not provide a letter to prove exclusion. It is the responsibility of the EPs and hospitals to self-attest and provide the reason of exclusion. Please see FAQ #6, #7, #8 for further information on claiming exclusion regarding the public health system(s) capacity.
Resources
CMS FAQ page: http://questions.cms.hhs.gov/app/answers/list/p/21,26,1058
Michigan EHR Incentive Program Website: http://www.michiganhealthit.org/
MDCH and Meaningful Use Testing: http://www.michiganhealthit.org/meaningful_use/publichealth.aspx