Reporting Period, Page 14:
Due to the many obstacles in meeting the Stage 2 objectives to date for patient engagement and direct messaging, as well as vendor challenges with delivering use-able, stable, compliant software, the shortened 90 day reporting period will allow providers an opportunity to successfully attest during the 2015 calendar year. The flexibility of the reporting period beginning outside of a specific calendar quarter is important for successful attestation in 2015 considering when this rule will be finalized.
Patient Engagement, Page 15:
I agree that the ability to test whether or not the physician has the functionality needed to interact with their patient (Secure Messaging and Timely Access) is a much better means of measuring patient engagement. Physicians have no control over the patient’s level of comfort towards allowing their health information to be published online or the adoption of messaging related to health matters. Adoption is increasing, but these two measures are definitely time intensive, can detract from the patient visit and often times require hiring additional personnel to make sure the provider does actually meet the measure threshold.
Patient Electronic Access, alternate proposal for threshold calculation, Page 50:
The measure for VDT (b) should be based on a denominator of patients with an office visit during the reporting period with a web account. Basing the threshold on patients that currently have an account would give the provider the appropriate denominator to calculate a meaningful threshold. Making this change would also normalize the data for comparison across providers. For example, you could compare a rural provider with an urban provider because the basis of the measurement is now equivalent.
Summary of Care, Page 67:
Exchanging C-CDA documents electronically has been a tremendous challenge for providers. While the providers that have the required CEHRT are able to create a compliant C-CDA and are able to send the document through direct messaging, other vendor systems are not necessarily able to receive that data in a readable format. It wasn’t until just recently that confirmation of receipt was available from the receiving entity because it required the receiving system to communicate through the HISP and then back into the receiving system. In light of these challenges, I request that you specifically define electronically. Does that include fax? Traditional email with encrypted attachments? Are there any other means you consider electronic?
In addition, will the exclusion posted in the Modifications to the Medicare and Medicaid Electronic Health Record (EHR) Incentive Program for 2014 and Other Changes to the EHR Incentive Program be upheld such that if the referral sources the provider is accustomed to using do not have direct messaging then the provider can claim an exclusion to this measure?
Public Health Options – Immunization Registry, Page 198:
The Immunization option under Public Health reporting reads as if only a bi-directional interface would count as successfully meeting this option – “receive immunization forecasts and histories”. Please clarify whether or not this is the case and if there will be any grandfathering of current registries. Most states are not able to exchange immunization data in a bi-directional manner and if required, this would pose a significant obstacle and financial hardship for providers to meet the public health option for immunization registry. To date, immunization registry reporting has been the most successful interoperability measure of meaningful use.
Public Health Options – Case Reporting, Page 198:
Cancer Registry reporting is one method of case reporting that many states support, but few CEHRT vendors are able to support. If a practice has purchased certified EHR technology that is unable to transmit to their state cancer registry, would they still be able to meet the definition of active engagement if they register their intent to participate with the state registry as soon as their EHR technology is able to transmit?
Providers need additional examples of case reporting and how they can actively engage in the event that they are excluded from all other public health options. Would a manual batch C-CDA export followed by a manual batch import or upload to a health organization meet the requirements for case reporting?
Public Health Options – Clinical Data Registry, Page 198
Can you further define clinical data registry? For example, if a CEHRT supports an extract, transform, and load process to move data from the client database to a cloud based data warehouse so that the data can be normalized, analyzed and reported on in various methods (PQRS, CQMs, PCMH, etc.), would that meet the definition of clinical data registry reporting?