New FAQs Clarify More EHR Meaningful Use Measures

The Centers for Medicare and Medicaid Services has added five new Frequently Asked Questions related to health information exchange and public health reporting requirements under the electronic health records meaningful use program, and updated an existing FAQ:

New EHR Meaningful Use Measures FAQs

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

Answer: 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.

In order to use an HIE for quality data collection, a state would need to develop infrastructure to capture electronic clinical quality measures through the Quality Reporting Data Architecture (QRDA) format. In addition, eligible professionals and hospitals would either have to generate the QRDA files using the provider’s Certified EHR Technology and/or the HIE itself would have to be certified as an EHR module for eCQMs.

The Office of the National Coordinator for Health Information Technology and CMS published a state-focused electronic clinical quality reporting toolkit to provide support for states developing the policy and IT infrastructure for electronic clinical quality measurement. Further, states can request Federal Financial Participation at the 90/10 HITECH rate to assist in building the infrastructure to submit eCQMs electronically for the Medicaid EHR Incentive program. For more information, please see the State Medicaid Directors Letter #11-004:
http://downloads.cms.gov/cmsgov/archived-downloads/SMDL/downloads/SMD11004.pdf.

New 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: 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 as follows:

• — The information required by a public health meaningful use objective must originate from the provider’s Certified Electronic Health Records Technology (CEHRT); and
• — The information sent from the provider’s Certified EHR Technology must be formatted according to the standards and implementation specifications associated with the public health meaningful use objective.

If a provider intends to use an intermediary as an extension of their CEHRT to satisfy a meaningful use requirement and not simply to transport the data, the intermediary would need to be certified as an EHR Module for that purpose.  When obtaining a CMS certification number from the Certified HIT Products List (CHPL), a provider would need to include the intermediary’s certification number during their attestation.

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Source: www.healthdatamanagement.com; Joseph Goedert; August 2, 2013.