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Stage 3 Meaningful Use Requires Infrastructure for PHAs, CDRs

By Kyle Murphy, PhD

- As part of the meaningful use's end-goal to leverage health IT in support of population health management, its next and final phase — Stage 3 Meaningful Use — requires a new approach to public health and clinical data registry reporting.

Of its eight total objectives, its eighth has the aim of building on Stage 2 Meaningful Use requirements for establishing lines of communication between eligible providers and public health agencies (PHAs) and clinical data registries (CDRs).

"Providers' use of certified EHR technology can increase the flow of secure health information and reduce the burden that otherwise could attach to these important communications," the proposed rule states. "The purpose of this Stage 3 objective is to further advance  communication between providers and PHAs or CDRs, as well as strengthen the capture  and transmission of such health information within the care continuum."

In the proposed rule, the Centers for Medicare & Medicaid Services (CMS) suggests a new measure for case reporting and terminology to complement this changing requirement. The eighth objective would require eligible providers to be "active engagement with a PHA or CDR to submit electronic public health data in a meaningful way using certified EHR technology, except where prohibited, and in accordance with applicable law and practice."

The notion of "active engagement" replaces the prior one of "ongoing submission" in response to meaningful use stakeholders who "noted that the ongoing submission requirement does not accurately capture the nature of communication between providers and a PHA or CDR, and does not consider the many steps necessary to arrange for registry submission to a PHA or CDR."

As defined in the proposed rule, active engagement refers to the process by providers to send actual production data to PHAs or CDRs.

CMS is proposing three avenues for eligible providers to take to satisfy the meaningful use requirement for active engagement.

The first option — completed registration to submit data — takes into account limitations that prevent PHAs or CDRs from reaching the testing and validating processes:

The EP, eligible hospital, or CAH registered to submit data with the PHA or, where applicable, the CDR to which the information is being submitted; registration was completed within 60 days after the start of the EHR reporting period; and the EP, eligible hospital, or CAH is awaiting an invitation from the PHA or CDR to begin testing and validation.

The second option — testing and validation — focuses on the ability of eligible providers to meet the request of PHAs or CDRs within a specified period of time:

The EP, eligible hospital, or CAH is in the process of testing and validation of the electronic submission of data. Providers must respond to requests from the PHA or, where applicable, the CDR within 30 days; failure to respond twice within an EHR reporting period would result in that provider not meeting the measure.

The third and final option is for eligible providers who have completed testing and validation and are actively sending production data to PHRs or CDAs electronically.

As part of the proposed rule, CMS claims that it will provide support to eligible providers "by creating a centralized repository of national, state, and local PHA and CDR readiness," which the federal agency championed as a benefit in final rulemaking for Stage 2 and now intends to move forward with.

"The centralized repository is integral to meaningful use and is expected to be available by the start of CY 2017," CMS states. "We expect that the centralized repository will include readiness updates for PHAs and CDRs at the state, local, and national level. We welcome your comments on the use and structure of the centralized repository."

If everything goes according to plan, an infrastructure for exchange of public health and clinical data via certified EHR technology should finally be in place.

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