On October 6, CMS released the final rule for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. To support provider participation in 2015, CMS has released two additional FAQs in response to inquiries about the public health reporting objective in 2015.
Question: For 2015, how should a provider report on the public health reporting objective if they had planned to be in Stage 1 meaningful use which required sending a test message and continued submission if successful, but did not require registration of intent?
Answer: We did not intend to require providers to engage in new activities during 2015, which may not be feasible after the publication of the final rule in order to successfully demonstrate meaningful use in 2015. Since providers in Stage 1 in 2015 were not previously required to submit a registration of intent to submit data to meet Objective 10 measures, providers may meet the measures by having sent a test message or by being in production. Providers who have sent a test message can be considered to have met Option 2 of Active Engagement – Test and Validation; providers who are in production can be considered to have met Option 3 of Active Engagement – Production.
Question: Does integration of the PDMP (Prescription Drug Monitoring Program) into an EHR count as a specialized registry?
Answer: If the PDMP within a jurisdiction has declared itself a specialized registry ready to accept data, then the integration with a PDMP can count towards a specialized registry. The EHR must be CEHRT, but there are no standards for the exchange of data.