Selected CMS and ONC FAQs

1. What steps does a provider have to take to determine if there is a specialized registry available for them, or if they should instead claim an exclusion?

2. What can count as a specialized registry?

3. What steps do eligible hospitals and Critical Access Hospitals need to take to meet the specialized registry objective? Is it different from EPs?

4. Does integration of the PDMP (Prescription Drug Monitoring Program) into an EHR count as a specialized registry?

5. If an EP, eligible hospital or Critical Access Hospital (CAH) is unable to effectively plan for a reporting period in 2015 due to the timing of the publication of the 2015 through 2017 Modifications final rule, can they apply for a hardship exception?

6. What should a provider do in 2016 if they did not previously intend to report to a public health reporting measure that was previously a menu measure in Stage 2 and they do not have the necessary software in CEHRT or the interface the registry requires available in their health IT systems? What if the software is potentially available but there is a significant cost to connect to the interface?

7. For 2016, what alternate exclusions are available for the public health reporting objective? Is there an alternate exclusion available to accommodate the changes to how the measures are counted?

8. For 2015, how should a provider report on the public health reporting objective if they had planned to be in Stage 1 meaningful use which required sending a test message and continued submission if successful, but did not require registration of intent?

9. For 2015, how should a provider report on the public health reporting objective if they had not planned to attest to certain public health measures? Is there an alternate exclusion available to accommodate the changes to how the measures are counted?

10. To meet public health objectives in the Medicare and Medicaid Electronic Health Records (EHR) Incentive Programs, when does the provider need to possess, own and/or install a Certified EHR Technology (CEHRT)?

11. For Stage 2 of the Medicare and Medicaid Electronic Health Records (EHR) Incentive Programs, is it acceptable for providers to register their intent with the Public Health Agency (PHA) prior to the start of their EHR reporting period?

12. To meet public health objectives in the Medicare and Medicaid Electronic Health Records (EHR) Incentive Programs, must providers register their intent to submit data for Stage 2 of Meaningful Use during each year of participation to meet the measure?

13. For the Stage 2 objectives of the Medicare and Medicaid Electronic Health Records (EHR) Incentive Programs that require submission of electronic data to Public Health Agencies (PHA), can a provider meet the objective even though they may not have successfully submitted data to the PHA for their entire EHR reporting period?

14. If an eligible professional (EP) or hospital meets an exclusion for a public health objective, does the EP or hospital need to have CEHRT that meets the certification criteria related to that public health objective?

15. If an eligible professional (EP) in the Medicare and Medicaid Electronic Health Records (EHR) Incentive Programs is part of a group practice that has achieved ongoing submission to a public health agency (PHA), but the EP himself/herself did not administer any immunizations to any of the populations for which data is collected by their jurisdiction's immunization registry during their EHR reporting period, can he/she attest to meeting the measure since they are part of the group practice that is submitting data to the registry?

16. For Meaningful Use (MU) Stage 2 menu objective of the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs can electronic data submission to Prescription Drug Monitoring Programs (PDMP) and to the CDC/National Center for Health Statistics (NCHS) provider surveys from the Certified Electronic Health Records Technology (CEHRT), be counted under the Meaningful Use (MU) Stage 2 menu objective for submission of data to specialized registries from Eligible Professionals?

17. For meaningful use objectives of the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs that require a provider to test the transfer of data, such as "capability to exchange key clinical information" and testing submission of data to public health agencies, can the eligible professional (EP), eligible hospital or critical access hospital (CAH) conduct the test from a test environment or test domain of its certified EHR technology in order to satisfy the measures of these objectives?

18. Must providers have their electronic health record (EHR) technology certified prior to beginning the EHR reporting period in order to demonstrate Meaningful Use under the Medicare and Medicaid EHR Incentive Programs?

19. For Stage 1 and 2 meaningful use objectives of the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs that require submission of data to public health agencies, if multiple eligible professionals (EPs) are using the same certified EHR technology across several physical locations, can a single test or onboarding effort serve to meet the measures of these objectives?

20. Where can I find a list of public health agencies and immunization registries to submit my data as required by the public health objectives for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs?

21. If an eligible hospital (EH) or critical access hospital (CAH) does not have any reportable lab results during the EHR reporting period (for example, the EH or CAH outsources all lab testing to a commercial lab or does not perform any lab tests for conditions that are reportable in their jurisdiction) can they be excluded from the requirement in the Electronic Health Records (EHR) Incentive programs to submit reportable lab results to a public health agency?

22. Can a public health agency use a Health Information Exchange (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)?

23. To meet the Stage 1 public health meaningful use objectives for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs, does a provider have to send information directly from their certified EHR technology to the appropriate receiving entity or can they use an intermediary such as a health information exchange (HIE) or another third-party software vendor?

24. 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

25. If a hospital operates in a jurisdiction where a public health agency (PHA) has the ability to accept certain reportable laboratory results electronically and in the required standards, but the hospital does not generate those particular reportable laboratory results, how must the hospital attest to the core measure for Electronic Reportable Laboratory Results?

26. If an Eligible Professional (EP) or hospital attesting to meaningful use (MU) in the Electronic Health Records (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?

27. For the meaningful use objective "Capability to submit electronic syndromic surveillance data to public health agencies," what is the definition of "syndromic surveillance"?

28. 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 health information exchange (HIE)?

29. Will the Centers for Medicare & Medicaid Services (CMS) conduct audits as part of the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs?

30. If my certified electronic health record (EHR) technology is capable of submitting batch files to an immunization registry using the standards adopted by the Office of the National Coordinator of Health Information Technology, is that sufficient to meet the Meaningful Use objective "submit electronic data to immunization registries" for the Medicare and Medicaid EHR Incentive Programs?

31. To meet the meaningful use objective "use certified EHR technology to identify patient-specific resources and provide those resources to the patient" for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs, does the certified EHR have to generate the education resources or can the EHR simply alert the provider of available resources?

32. 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?

33. How should eligible professionals (EPs) select menu objectives for the Medicare and Medicaid Electronic Health Records (EHR) Incentive Programs?

34. As an eligible provider seeking to demonstrate meaningful use of Certified EHR Technology (CEHRT), what options do I have to meet the Certified EHR Technology definition before and after 2014?

35. I use or would like to use an “interface” to submit data to a public health agency/registry. Does this interface need to be certified?