FAQ on Meaningful Use

Frequently Asked Questions about Meaningful Use

In October 2015, the Centers for Medicare & Medicaid Services (CMS) released a final rule that specifies reporting requirements for eligible professionals (EPs) who are participating in the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. The final rule detailed changes that CMS made in an effort to streamline and simplify the programs and offer more flexibility.

The following are frequently asked questions (FAQs) about the EHR Incentive Programs in 2015 through 2017.

Reporting Period

Q: How did the final rule change the electronic health record (EHR) reporting period?

A: In 2015, the reporting period for all eligible professionals (EPs) is 90 continuous days.

Beginning in 2016, the EHR reporting period will be based on the calendar year. All providers will be required to report for January 1 through December 31 of the calendar year. However, EPs attesting for the first time in 2016 will be allowed to report for a continuous 90-day period. All returning participants must report for the full calendar year (January 1, 2016–December 31, 2016).

In 2017, Medicaid providers demonstrating meaningful use for the first time will be allowed to report for a continuous 90-day period. All other EPs must report for the full calendar year (January 1, 2017–December 31, 2017).

Q: Is reporting for a three-month period the same as reporting for 90 days?

A: No. A three-month period may include fewer or more than 90 days. The Centers for Medicare & Medicaid Services (CMS) specifically states that the reporting period must be a full 90 continuous days. In addition, CMS allows providers to begin and end their 90-day reporting period at any point during a month. Reporting for a three-month period would reduce flexibility by tying the reporting period to the beginning and end of the month.

Q: What if I am unable to meet the full calendar year reporting period?

A: Eligible professionals who are unable to meet the full calendar year reporting requirement can apply for a hardship exception if circumstances beyond the EP’s control prevent him or her from reporting. CMS reviews these applications on a case-by-case basis.

“Topped-Out” Measures

Q: What is a “topped-out” measure?

A: The Centers for Medicare & Medicaid Services (CMS) defines a topped-out measure as a measure that has “achieved widespread adoption at a high rate of performance and no longer represent[s] a basis upon which provider performance may be differentiated.” Measures that are topped out or redundant are removed from CMS reporting requirements.

Q: If a measure has been removed because it is topped out or redundant, do I still have to capture data on it?

A: While CMS no longer requires you to report on topped out or redundant measures, you are still encouraged to continue capturing data on these measures.

Q: Will I still be able to capture data in my electronic health record (EHR) on topped-out or redundant measures?

A: Yes. The data standards and functions for topped-out and redundant measures will remain part of the certification criteria for EHRs.

Q: Can I substitute a topped-out measure if I am unable to meet one of the required measures?

A: No. CMS will not accept reporting on any topped out or redundant measure.

Reporting Requirements

Q: What do I have to report for the Electronic Health Record (EHR) Incentive Programs in 2015 through 2017?

A:  For 2015 through 2017, you will report on nine objectives and one public health objective. The final rule removed the distinction between core and menu objectives.

Q: Will alternate measures and exclusions be available to providers after 2015?

A: Providers attesting for the first time in 2016 will have two alternate exclusions available to them. They can claim an alternate exclusion for Measure 2 and Measure 3 of the computerized provider order entry (CPOE) objective.

Q: If I choose to use an alternate exclusion for one of the objectives, what proof is required to verify that I did not intend to attest to the objective? Will the Centers for Medicare & Medicaid Services (CMS) audit me?

A: No. If you claim an exclusion for an objective, CMS does not require documentation that you did not intend to attest to that objective.

Q: Some measures are based on actions for unique patients. Can I count actions that occurred before or after the reporting period?

A: If the patient action occurred outside of the reporting period and in a different calendar year, it will not satisfy the numerator requirements. However, if the action occurred outside of the reporting period but within the same calendar year, it can count toward the numerator. For example, if your reporting period is 90 continuous days, a patient action that occurs before or after the 90-day period and within the same calendar year can count toward the numerator. However, it is important to note that if you are attesting prior to the end of the calendar year, the patient action must occur before attestation is completed.

Q: Is reporting on clinical quality measures (CQMs) still required?

A: Yes. Providers must report on nine CQMs, and the measures selected must cover at least three National Quality Strategy (NQS) domains. For 2015, the reporting period for CQMs is 90 continuous days. However, providers who are electronically reporting CQMs for multiple programs (e.g., EHR Incentive Program and Physician Quality Reporting System [PQRS]) must report for a full calendar year.

Modified Stage 2, Objective 1: Protect Patient Health Information

Q: Are alternate exclusions available for small practices?

A: No. The Centers for Medicare & Medicaid Services (CMS) does not offer exclusions for this measure. It is required for all eligible professionals (EPs) attesting to meaningful use.

Q: How often do I have to conduct a security risk assessment?

A: A security risk assessment must be conducted or reviewed each year and should cover the entire year for which the assessment is conducted/reviewed. If the reporting period is less than a full calendar year, the assessment can occur before or after the reporting period. However, the assessment must occur within the same calendar year as the reporting period. If you are attesting before the end of the year, the security risk assessment must be completed prior to your attestation date.

Modfied Stage 2, Objective 2: Clinical Decision Support

Q: There is an exclusion for the Measure 2 for any eligible professional (EP) who writes fewer than 100 prescriptions. Does this cover the full calendar year or just the reporting period?

A: The exclusion does not specify the length of the electronic health record (EHR) reporting period. It just states that a provider can be excluded if he or she writes fewer than 100 prescriptions during the reporting period.

Modified Stage 2, Objective 3: Computerized Provider Order Entry

Q: Who is considered a credentialed user?

A: The following qualify as credentialed users:

  • Licensed health care professionals
  • Credentialed medical assistants
  • Medical staff members credentialed to perform duties equivalent to a credentialed medical assistant
  • Interns who have completed their medical training and are working toward appropriate licensure.

The user must be credentialed by an entity that is separate from the employer. The Centers for Medicare & Medicaid Services (CMS) defers to providers to determine, on the basis of CMS guidelines, whether a staff member is appropriately credentialed to have the clinical training, knowledge, and experience required to enter orders. A specific job title is not required; however, CMS states that a scribe does not meet the requirements for a medical staff member who may enter orders for the purposes of the computerized provider order entry (CPOE) objective.

Q: Am I required to include standing orders in the CPOE numerator and denominator?

A: No. CMS allows providers to exclude orders that are predetermined for a given set of patient characteristics or for a given procedure.

Modified Stage 2, Objective 4: Electronic Prescribing

Q: Does the measure for this objective include electronic prescribing of controlled substances?

A: Controlled substances are no longer excluded from the definition of “permissible prescriptions.” Providers may include prescriptions for controlled substances in the denominator if electronic prescription of a specific medication or schedule of medications is permissible under state or federal law.

Q: What if no formulary is available for a prescription?

A: If no formulary is available, you may still count the patient in the numerator for the electronic prescribing measure.

Modified Stage 2, Objective 5: Health Information Exchange (previously Summary of Care)

Q: What is included in a summary of care?

A: A summary of care should include the following information, if the provider knows it:

  • Patient name
  • Referring or transitioning provider’s name and office contract information
  • Procedures
  • Encounter diagnosis
  • Immunizations
  • Laboratory test results
  • Vital signs (height, weight, blood pressure, body mass index [BMI])
  • Smoking status
  • Functional status, including activities of daily living, and cognitive and disability status
  • Demographic information (preferred language, sex, race, ethnicity, date of birth)
  • Care plan field, including goals and instructions
  • Care team, including the primary care provider of record and any additional known care team members beyond the referring or transitioning provider and the receiving provider
  • Reason for referral

In some cases, there may be no information available to populate one or more of the fields, either because the provider can be excluded from recording such information or because there is no information to record. In such cases, the provider may leave the field(s) blank. However, at minimum, a provider must record:

  • Current problem list (providers may also include historical problems at their discretion)
  • Current medication list
  • Current medication allergy list

Eligible professionals (EPs) must verify that these three fields are not blank and include the most recent information known by the EP when the summary of care document is generated.

Q: Are all labs included in laboratory test results?

A: A provider must have the ability to send all laboratory test results in the summary of care document. However, the provider can use his or her discretion to send the most appropriate results for a given referral or transition. A provider must send all laboratory test results at the request of the receiving provider or the patient.

Q: What constitutes a transition of care for this objective?

A: For this objective, a transition of care is defined as a transition or referral in which the referring provider is recognized as a different billing identity for the Electronic Health Record (EHR) Incentive Programs than the receiving provider.

Q: What if I push the summary of care document out to my health information exchange (HIE)?

A: As the referring provider, you must have reasonable certainty that a summary of care document was received. You may count the use of the HIE in the numerator if you can confirm that a query was made by the receiving provider, but simply publishing the document to your HIE is insufficient to meet the measure for this objective.

Modified Stage 2, Objective 6: Patient-Specific Education

Q: What is the timeframe for providing patient-specific education? For example, if a patient received a diagnosis for a chronic condition in the previous reporting period, do I need to provide education on the condition to him or her each year?

A: This action must take place no earlier than the start of your reporting period and no later than your attestation date. Regardless of how many visits the patient has within the reporting period, you can meet the minimum requirements by providing patient-specific educational materials to him or her one time during the reporting period. Provision of patient-specific education is not limited to an office visit; it may occur at any point during the reporting period.

Patient education provided at the initial diagnosis of a chronic condition will not count for the numerator in perpetuity. If a patient who has a chronic condition has an office visit during the reporting period, he or she must receive some form of patient-specific education. However, it does not have to be related to the patient’s chronic condition.

Q: Does education have to be provided to the patient electronically?

A: Patient-specific resources must be identified by the certified electronic health record technology (CEHRT), but the Modified Stage 2 measure for this objective does not state that the education must be provided to the patient electronically.

Modified Stage 2, Objective 7: Medication Reconciliation

Q: What is the definition of medication reconciliation?

A: The Centers for Medicare & Medicaid Services (CMS) defines medication reconciliation as “the process of identifying the most accurate list of all medications that the patient is taking, including name, dosage, frequency, and route, by comparing the medical record to an external list of medications obtained from a patient, hospital, or other provider.”

Q: What constitutes a transition of care for the medication reconciliation objective?

A: For this objective, a transition of care is defined as the movement of a patient from one setting of care (for example, a hospital, ambulatory primary care practice, ambulatory specialty care practice, long-term care, home health care, rehabilitation facility) to another. Movement of a patient between providers who are recognized as different billing identities (as defined under the Electronic Health Record [EHR] Incentive Programs) also constitutes a transition of care. In addition, referrals are defined as cases in which a patient is referred to another provider, but the referring provider continues to provide care for the patient.

Q: Are new patients included? If so, what is the definition of a new patient?

A: Yes, new patients are included in the denominator for this objective’s measure. The provider must complete medication reconciliation at the first encounter with a new patient. New patients include all patients who have never before been seen by the provider.

Q: Does the measure include referrals that are not received electronically?

A: Yes. In addition, medication reconciliation should occur with the transition or referral of the patient and is not dependent upon receipt of an electronic referral or summary of care document.

Modified Stage 2, Objective 8: Patient Electronic Access

Q: What information must be made available to the patient?

A: The following information must be made available to the patient electronically within four business days of the information becoming available to the eligible professional (EP):

  • Patient name
  • Provider’s name and office contact information
  • Current and past problem list
  • Procedures
  • Laboratory test results
  • Current medication list and medication history
  • Current medication allergy list and medication allergy history
  • Vital signs (height, weight, blood pressure, body mass index [BMI], growth charts)
  • Smoking status
  • Demographic information (preferred language, sex, race, ethnicity, date of birth)
  • Care plan field(s), including goals and instructions
  • Any known care team members, including the primary care provider of record

Q: If my patient population is highly unlikely to access personal health information online, do I still have to make it available?

A: Yes. Information must be made available to all patients, regardless of whether or not they are able or likely to access online information. The Centers for Medicare & Medicaid Services (CMS) also states that a patient who opts out or does not have an email address is not excluded from the denominator for Measure 1 of this objective. You can still satisfy Measure 1 by informing the patient how to access his or her health information online and how to opt in.

Q. Who qualifies for an exclusion to Measure 2 of this objective?

A. A provider qualifies for an exclusion if he or she conducts 50 percent or more of his or her patient encounters in a county in which 50 percent or more of the housing units do not have 4Mbps broadband availability according to the latest information available from the Federal Communications Commission (FCC) on the first day of the reporting period.

Q: Does information need to be made available to the patient for all encounters during the reporting period?

A: Yes. The patient must have timely access to updated information related to his or her care for each encounter that takes place during the electronic health record (EHR) reporting period. Patients seen during the reporting period who are not enrolled at the initial visit or are not given timely access to information from the initial visit cannot be counted in the numerator.

Q: What if a patient accesses his or her information outside of the reporting period?

A: Patient access can be counted for Measure 2 if the action occurred within the same calendar year as the reporting period and prior to attestation.

Q: What is the phased approach for Measure 2?

A: For 2015 and 2016, CMS is setting the threshold for Measure 2 at one patient viewing or downloading his or her health information, or transmitting it to a third party. This will allow providers additional time to adopt the proper technology. Beginning in 2017, the threshold will be set at 5 percent of all unique patients seen by the EP during the reporting period.

Modified Stage 2, Objective 9: Secure Messaging

Q: If my patient population is highly unlikely to send electronic messages (e.g., elderly, ill, low-income, rural), do I qualify for an exclusion from this objective?

A: You may qualify for an exclusion from this objective if you conduct 50 percent or more of your patient encounters in a county in which 50 percent or more of the housing units do not have 4Mbps broadband availability according to the latest information available from the Federal Communications Commission (FCC) on the first day of the reporting period.

Q: What is the phased approach for the secure messaging objective?

A: To allow providers time to work toward a goal of greater patient involvement, the Centers for Medicare & Medicaid Services (CMS) is using a phased approach to increase the threshold for this objective’s measure. In 2015, the capability for patients to send and receive secure electronic messages must be fully enabled for the entire reporting period. In 2016, at least one patient (or an authorized representative) must receive a response to a patient-initiated message or be sent a message electronically. Beginning in 2017, the threshold will increase so that more than 5 percent of patients (or their patient-authorized representatives) must receive or send a secure electronic message.

Modified Stage 2, Objective 10: Public Health

Q: What is the difference between ongoing submission and active engagement?

A: The Centers for Medicare & Medicaid Services (CMS) modified the public health reporting objective to offer flexibility to providers. For the Electronic Health Record (EHR) Incentive Programs in 2015 through 2017, “active engagement” replaces the ongoing submission requirement. Any action acceptable under the Stage 1 or Stage 2 public health reporting objectives counts toward meeting this active engagement requirement.

Providers have three options for active engagement:

Option 1: Completed registration to submit data

  • The eligible professional (EP) registered to submit data with the public health agency (PHA) or, where applicable, the clinical data registry (CDR) to which the information is being submitted. (Note: Providers who have registered in previous years do not need to submit additional registrations in subsequent EHR reporting periods to meet this requirement.)
  • Registration was completed within 60 days of the start of the EHR reporting period.
  • The EP is awaiting an invitation from the PHA or CDR to begin testing and validation.

Option 2: Testing and validation

  • The EP is in the process of testing and validation of electronic submission of data.
  • Providers must respond to requests from the PHA or, where applicable, the CDR within 30 days.
  • A provider who fails to respond twice within the EHR reporting period does not meet the measure.

Option 3: Production

  • The EP has completed testing and validation of electronic submission and is electronically submitting production data to the PHA or CDR.

Q: Do I have to register for each measure?

A: Yes. You must register with the appropriate PHA or CDR for each measure you intend to use to meet meaningful use requirements. Registration for purposes of Option 1 for active engagement will only count if the provider has not attested to the measure in a previous EHR reporting period.

Q: Can I attest to a measure if I am part of a group that has registered with a PHA or CDR?

A: A provider can attest to a measure if he or she has registered as an individual or is part of a group that has registered with a PHA or CDR. If a provider who is part of a group uses the same certified electronic health record technology (CEHRT) as the group, he or she may attest using documentation provided to the practice or organization.

Q: What are the alternate exclusions available in 2015?

A: Providers scheduled to attest to Stage 1 for 2015 must attest to at least one measure and may claim up to two exclusions for any of the three measures. The EP must attest to the remaining measure or meet the exclusion requirements for it.

Providers scheduled to attest to Stage 2 for 2015 must attest to at least two measures and may claim one alternate exclusion for either Measure 1 or Measure 2. The EP must attest to the remaining measures or meet the exclusion requirements for them.

Q: What if I report to more than one specialized registry?

A: You may count specialized registry reporting for up to two measures.

Q: Is reporting to a cancer registry still an option under this objective?

A: Yes. CMS has incorporated cancer registry reporting into specialized registry reporting. If you report to more than one specialized registry, you may count specialized registry reporting for up to two measures.

The following are frequently asked questions (FAQs) about Stage 3 of the EHR Incentive Programs in 2017 and subsequent years.

Q: Do I have to attest to Meaningful Use Stage 3 in 2017?

A. No. Stage 3 requirements are optional in 2017.

Q. What is the reporting period for Stage 3?

A: Providers who opt to attest to Stage 3 in 2017 will report for 90 continuous days. In 2018, Medicaid providers who are attesting for the first time will have a 90-day reporting period. All other providers attesting to Stage 3 in 2018 must report for a full calendar year.

Stage 3, Objective 1: Protect Patient Health Information

Q: How has the Stage 3 measure for this objective changed from the Modified Stage 2 measure?

A: The Centers for Medicare & Medicaid Services (CMS) added a requirement for implementation of appropriate technical, administrative, and physical safeguards. Additionally, eligible professionals (EPs) must conduct a security risk assessment upon the installation or upgrade of certified electronic health record technology (CEHRT).

Q: What is necessary to “correct identified security deficiencies”?

A: An EP must be able to show a plan for correcting or mitigating deficiencies, as well as steps that are being taken to implement the plan.

Stage 3, Objective 2: Electronic Prescribing

Q: What are the requirements for querying a formulary?

A: This objective’s measure requires providers to query through an automated process via their certified electronic health record technology (CEHRT). If a query yields no results, a provider is not required to conduct any further queries (e.g., manual or paper-based query) to satisfy the numerator.

Q: Are over-the-counter (OTC) medications included in the definition of permissible prescriptions?

A: No. OTC medications are excluded from the definition of permissible prescriptions. A prescription is defined as the “authorization by a provider to dispense a drug that would not be dispensed without such authorization.” A permissible prescription includes any medication that meets the definition of a prescription and is not listed as a controlled substance in Schedules II-V; however, controlled substances can be included if creation of a prescription for the medication via CEHRT is feasible and if it is permissible by state law.

Stage 3, Objective 3: Clinical Decision Support

Q: What constitutes a “relevant point of care”?

A: The Centers for Medicare & Medicaid Services (CMS) defines a relevant point of care as a point in the workflow at which the clinical decision support (CDS) intervention can influence clinical decision making before diagnostic or treatment action is taken in response to the intervention. CDS does not have to occur during the patient visit; however, it must occur at a point that meets the definition of a “relevant point of care.”

Q: Does each CDS intervention need to be linked directly to a clinical quality measure (CQM)?

A: No. Providers who cannot identify CQMs that are applicable to their scope of practice or patient population may implement CDS interventions that are related to high-priority health conditions relevant to their patient population and will be effective in improving the quality, safety, or efficiency of patient care. The conditions must be selected prior to the start of the electronic health record (EHR) reporting period.

Q: What if my EHR does not have alerts available for the measures I want to report?

A: CDS is not limited to computerized alerts or reminders for providers and patients. It can also include the following:

  • Clinical guidelines
  • Condition-specific order sets
  • Documentation templates
  • Focused patient data reports and summaries
  • Contextually relevant reference information

In addition, CDS is not limited to providers and nurses. It can also apply to support staff, patients, and other caregivers.

Q: What if I cannot meet the requirement to implement five CDS interventions?

A: There is no exclusion available for eligible professionals (EPs) who are unable to meet the five-intervention threshold. However, providers have the option of selecting CDS interventions related to high-priority health conditions if they cannot identify CQMs that are applicable to their scope of practice or patient population.

Q: Do the same interventions have to be in place for the entire reporting period?

A: No. An EP has the flexibility to choose different interventions throughout the reporting period as long as at least five CDS interventions are in place at any given time in the reporting period. Providers are encouraged to update their CDS selections as appropriate to meet the needs of their patient population.

Stage 3, Objective 5: Patient Electronic Access to Health Information

Q: What is an API and is it required?

A: An API is an application programming interface. An API allows a patient to use a third-party application to pull certain parts of his or her health information directly from the provider’s certified electronic health record technology (CEHRT). Meaningful Use Stage 3 requires EPs to provide access for patients to view or download their health information or transmit it to a third party. Providers are required to provide access to the information via any application of a patient’s choice that is configured to meet the technical specifications of the API in the provider’s CEHRT.

Q: How is the security of an API managed?

A: All providers are required to complete an annual security risk assessment, which would include assessment of an API in the provider’s CEHRT.

Q: What constitutes timely access?

A: The provider must provide a patient with access to the patient’s health information within 48 hours of the information becoming available.

Q: Utilization of my patient portal is low. Can I provide paper-based educational materials to my patients and still meet Measure 2 of this objective?

A: No. Although you may still provide paper-based educational materials to your patients, this action will not meet the numerator requirements for Measure 2.

Stage 3, Objective 6: Coordination of Care through Patient Engagement

Q: Do I have to report all three measures?

A: You must attest to all three measures, but you only have to meet the threshold for two of the three measures.

Q: What constitutes communication under Measure 2?

A: Under Measure 2, communication includes patient-to-provider messaging or provider-to-patient messaging. In order for messages to qualify as patient-to-provider communication, the provider must respond to the patient. Communication among members of a patient’s care team can satisfy this measure as long as the patient is engaged and has the opportunity to be an active participant in the conversation. If the initial action prompts additional communication among the care team members with the patient included, it is up to the provider’s discretion to exclude the patient from a particular message in order to prevent harm. However, once a patient is excluded from a message, all subsequent actions related to that message do not count toward the numerator for Measure 2.

Q: Are there guidelines on what the messages should contain?

A: Messages should be related to a patient’s health information. Messages regarding billing, scheduling, or other administrative processes do not satisfy this measure.

Q: What are data from a “non-clinical setting”?

A: Data from a non-clinical setting are generally defined as data from a setting in which the provider does not qualify as an eligible professional (EP) under the Electronic Health Record (EHR) Incentive Programs definition and does not have shared access to the EP’s certified electronic health record technology (CEHRT). Providers in non-clinical settings include, but are not limited to, nutritionists, physical therapists, occupational therapists, psychologists, and home health care providers. Data obtained directly from the patient also would qualify as data from a non-clinical setting.

Q: What types of data are included?

A: Data include, but are not limited to, the following:

  • Social service data
  • Data generated by the patient, or his or her authorized representative
  • Advance directives
  • Medical device data
  • Home health monitoring data
  • Fitness monitor data

Sources of data can include mobile applications for tracking health information and nutrition, home health devices with tracking capabilities (e.g., scales, blood pressure monitors), and wearable devices (e.g., activity trackers, heart monitors).

Q: How are data incorporated?

A: The Centers for Medicare & Medicaid Services (CMS) does not specify how the data should be incorporated into the provider’s CEHRT.  A provider may work with his or her CEHRT vendor to incorporate data in a structured format or through the Consolidated-Clinical Document Architecture (C-CDA), or the provider may elect to include the data through attachments, links, and text references.

Stage 3, Objective 7: Health Information Exchange

Q: Do the measures for this objective include self-referrals?

A: It is up to the provider’s discretion whether to include self-referrals in Measure 1 of this objective. Self-referrals must be treated like any other referral for Measure 2 and Measure 3 of the objective. For self-referrals, an eligible professional (EP) may count the patient in the numerator if the EP takes action to retrieve a summary of care record from the provider from whom the patient received care initially.

Q: What constitutes a different setting of care?

A: One setting of care is distinguished from another if the providers involved in the transition or referral have different billing identities within the Electronic Health Record (EHR) Incentive Programs (e.g., different National Provider Identifiers [NPIs]).

Q: Can I exclude patients in cases in which the referring provider and receiving provider have access to the same certified electronic health record technology (CEHRT)?

A: Providers who share access to the same CEHRT but have different billing identities may include transitions or referrals in the numerator and denominator if the referring provider creates and sends a summary of care document. A transition or referral should not be included in the numerator if the receiving provider simply accesses the patient’s health information in the CEHRT. This is a change from the objective in Modified Stage 2, which specifies that patients transitioning between providers who share access to the same CEHRT can be excluded from the denominator.

Q: How are the summary of care requirements different for Stage 3?

A: In addition to including all of the summary of care elements required for Modified Stage 2, providers must capture unique device identifiers (UDIs) for implantable medical devices. For the problem list, Stage 3 allows providers to use their discretion to include items that they feel are pertinent and relevant to the patient’s care rather than sending an inclusive list of active and resolved problems. Providers can also use their clinical judgement to decide whether to include the patient’s medical history list and surgical history list.

Q: What if I did not receive an electronic summary of care for a patient?

A: A patient may be excluded from the denominator if the provider determines that an electronic summary of care is unavailable. An electronic summary of care is considered unavailable if the provider requests one but does not receive it and then does one of the following:

  • Queries at least one external source via health information exchange (HIE) functionality but does not locate a summary of care for the patient

OR

  • Confirms that HIE functionality to conduct a query is not operational in his or her geographic region and is not available within the EHR network at the start of the reporting period

Q: For Measure 3, what information is included in the clinical information reconciliation?

A: Clinical information reconciliation must be implemented for a patient’s current medication list, current medication allergy list, and current problem list.

Q: Does sending a summary of care by “any electronic means” include transmission via pdf or electronic fax?

A: No. The Centers for Medicare & Medicaid Services (CMS) states that the sending provider must send the summary of care in a format that would allow the receiving provider to incorporate the information electronically into his or her CEHRT. If a receiving provider converts the information into a pdf or another format, the sending provider may still count the transition or referral in the numerator because the information was sent in a format that could be electronically incorporated.

Stage 3, Objective 8: Public Health and Clinical Data Registry Reporting

Q: How far in advance will I know if there is a public health registry (PHA) in my area that has declared readiness?

A: At least six months prior to the first day of the electronic health record (EHR) reporting period, public health agencies should declare whether the registry they are offering will be ready on January 1 of the upcoming year for use by providers. A provider can claim an exclusion if PHAs in his or her area have not declared readiness six months prior to the EHR reporting period.

Q: How is the immunization registry measure different in Stage 3?

A: For Stage 3, the immunization registry measure requires bi-directional data exchange. In other words, providers must be able to send immunization data to the registry from their certified electronic health record technology (CEHRT), and they must also be able to receive data from the registry.

Q: How is the syndromic surveillance registry measure different for Stage 3?

A: For eligible professionals (EPs), the syndromic surveillance registry measure is now limited to EPs who practice in an urgent care setting.

Q: Is specialized registry reporting still available in Stage 3?

A: Yes. The Centers for Medicare & Medicaid Services (CMS) has split the Modified Stage 2 measure of reporting to a specialized registry into two measures:

  • Measure 4: Public health registry reporting
  • Measure 5: Clinical data registry reporting

A public health registry is defined by CMS as “a registry that is administered by, or on behalf of, a local, state, territorial, or national public health agency and [that] collects data for public health purposes.” Cancer case reporting is an option under the public health registry reporting measure. A provider may also count specialized registry reporting under the public health registry reporting measure if he or she achieved active engagement under Option 3: Production with a specialized registry in a prior year under the meaningful use requirements in 2015 through 2017.

CMS defines a clinical data registry as a registry that is “administered by, or on behalf of, other non-public health agency entities.”