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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.

Public Health Menu Measures – Meaningful Use Monday

Posted on July 25, 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.

When selecting the 5 meaningful use menu measures on which to report—from the list of 10 possibilities—the only constraint is that the EP must include at least one of the two measures from the “public health” category:

 These two measures have a number of things in common:

  • EPs report by attesting that “Yes” a test was performed. There is no numerator and denominator to report and consequently no thresholds to meet.
  • One test is sufficient for a group of providers that share a certified EHR in the same setting – it is not necessary for each EP to conduct a test individually.
  • The test does not have to be successful to meet the measure.
  • If the test is successful, then the EPs should continue to report on a regular basis.

 Both measures allow EPs to claim an exclusion under specified circumstances:

  • Immunizations Measure:  The EP does not perform immunizations OR none of the immunization registries to which he/she would submit the information are able to receive the information electronically.
  • Syndromic Surveillance Measure: The EP does not collect any reportable information OR there is no public health agency that is able to receive the information electronically.

 The potential to exclude these measures has resulted in some confusion about which—and how many—of these measures to report. The next Meaningful Use Monday post will offer some guidance on this issue.

Meaningful Use Measures: Timely Electronic Access to Health Information – Meaningful Use Monday

Posted on July 18, 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.

Meaningful Use Menu Measure: At least 10% of all unique patients seen by the eligible professional (EP) are provided timely (available to the patient within 4 business days) electronic access to their health information.

This is a third meaningful use measure related to providing patients with access to their health information. Meaningful Use Mondays has already addressed the two core measures—clinical summary and electronic copy of health information—“timely access” is a menu measure.

 The requirements are as follows:

  • The measure includes a provision for EPs to claim an exclusion, but I don’t believe that many will qualify for this exclusion. They would have to attest that they “neither order nor create lab tests or information that would be contained in the problem list, medication list, medication allergy list, etc.”—a fact that would make meeting the core meaningful use measures quite unlikely.
  • Access to patient information must be provided online, via a portal or a personal health record (PHR)—in contrast to the other two patient-related, access-to-information measures, which allow the use of various types of electronic media and/or paper.
  • The denominator is “all unique patients seen during the reporting period.” Therefore, in order for that patient to be counted in the numerator, every time any piece of clinical information that can reside in the EHR is added to the patient’s chart, the portal must be updated within 4 days of the EP’s receipt of that information.
  • This measure assesses the availability of timely access. It does not matter—for meaningful use purposes—whether patients request, or ever access, the information.

A challenge associated with this measure is securing patient consent to have clinical information posted on an online portal and then getting a sufficient number of patients to register. Because it is a menu measure, EPs can choose to omit this measure in Stage 1, and it appears—from my conversations with providers and with CMS—that many are planning to do just that!

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.