Public Health Measures: Meet, Exclude, or Defer? – Meaningful Use Monday

Posted on August 1, 2011 I Written By

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money.

Lynn Scheps is Vice President, Government Affairs at EHR vendor SRSsoft. In this role, Lynn has been a Voice of Physicians and SRSsoft users in Washington during the formulation of the meaningful use criteria. Lynn is currently working to assist SRSsoft users interested in showing meaningful use and receiving the EHR incentive money. Check out Lynn’s previous Meaningful Use Monday posts.

Last week’s Meaningful Use Monday identified the two meaningful use public health measures—electronic reporting of immunizations and electronic reporting of syndromic surveillance data—at least one of which EPs must include among their 5 menu measures. So, what do you do if you can’t meet one or both of the public health measures? 

The requirement: EPs must accomplish at least one of these measures or they must exclude both. Another way to look at this is: If an EP attests to an exclusion for one of the measures, then the EP must attest to either accomplishing or excluding the other. What the EP cannot do is exclude one and then skip (“defer”) the other. (Examples of acceptable and unacceptable scenarios are described below.) 

There is a difference between “excluding” a measure and “deferring” a measure:

  • To exclude a measure, the EP must meet the criteria for exclusion as spelled out in the definition of the measure. Example: an EP does not collect any reportable (i.e., syndromic surveillance) information, or there is no agency that can accept this information electronically. Excluding a measure counts as meeting the measure.
  • Defer is the CMS term for electing to skip this measure, i.e., not count it as one of the EP’s 5 menu measures. (The term “defer” implies that the EP is postponing compliance to Stage 2.)

 Acceptable scenarios:

  • Accomplish both public health measures.  This satisfies 2 of the 5 menu measures required for meaningful use.
  • Accomplish one of the public health measures and defer (skip) the other measure. This satisfies 1 of the 5 menu measures.
  • Accomplish one of the public health measures and exclude the other (assuming the EP meets the criteria for exclusion). This satisfies 2 of the 5 menu measures.  Note: Although CMS prefers that EPs not use up measures with exclusions if there are measures for which they have actual data or experience to report, the rules do not require EPs to do so.
  • Exclude both public health measures (assuming the EP meets the criteria).

 Unacceptable scenario:

  • Exclude one public health measure and defer the other. For example, an EP’s local public health agencies cannot accept syndromic surveillance information, but there are local registries that can accept immunization information. If this EP excludes syndromic surveillance, he/she would have to also report on immunizations—either by meeting the measure or by attesting to an exclusion.