Last week we looked at the core measures without a threshold in the CMS EHR incentive program. Today we’ll examine measures on the menu without a threshold. As you may recall, in addition to the 15 core objectives, each provider must select 5 of the 10 menu objectives to report in order to demonstrate meaningful use. There is one minor nuance when selecting the 5 menu objectives to report; at least one of those selected must be a public health related objective (number 3 or 4 below).
As with the core objectives, the menu objectives can be divided into two broad categories: those with a threshold that must be met and those without a threshold. Again, measures in this later group are asking the provider to attest to the fact the objective was met, typically a minimum of once during the reporting period. There are 4 objectives without a threshold on the menu:
1. Drug-formulary checks
2. Generate a patient list
3. Immunization registry
4. Syndromic surveillance
Verify drug-formulary checks were turned on
Very similar to the drug-drug and drug-allergy core objective, this measure asks the provider to attest to the fact the drug-formulary checking feature within the e-prescribing tool is “turned on” for the entire reporting period. All certified EHRs (and stand alone eRx tools for those of you taking the modular route to meaningful use) posses a drug-formulary checking feature. This measure is another low hurdle to clear in the EHR incentive program.
Generate a patient list
This objective requires the provider to attest to the fact that during the reporting period the EHR was utilized to generate at least one patient list. A patient list in this context is a list of patients generated using various attributes such as a medication, diagnosis on the problem list, demographic or lab result (e.g., create a list of all CKD stage 4 patients with an iPTH > 110). All certified EHRs have the ability to generate patient lists—yet another low bar to clear.
Submit data electronically to an immunization registry
This measure is asking the provider to attest to the fact that they tested the EHRs ability to submit immunization information electronically to a local immunization registry or to an immunization information system at least one time before the end of the EHR reporting period. As with the core measure related to the exchange of key clinical data (reviewed last week), meeting this measure can be accomplished with actual patient data or using “dummy data.” Another similarity between these two measures applies to group practices using the same EHR: a successful transmission by one provider during the reporting period will satisfy this measure for every provider in the group using the EHR. Every certified-complete EHR is capable of creating the export for this measure utilizing the appropriate standard. Providers that do not administer immunizations are excluded from reporting this measure.
Report syndromic surveillance electronically to a public health agency
The last measure on our list today is asking the provider to attest to the fact that at least one time prior to the end of the reporting period they tested the EHRs ability to send syndromic surveillance data electronically to a public health entity. What is syndromic surveillance? An example would be identifying all of the provider’s patients with the diagnosis of H1N1 during a certain time interval. Who are the eligible public health agencies? This list is long, quoting from the final rule: “A public health agency is an entity under the jurisdiction of the U.S. Department of Health and Human Services, tribal organization, State level and/or city/county level administration that serves a public health function.” As with the immunization measure, the test can be accomplished with actual data or test data, and group practices using the same EHR are only required to complete the measure for a single provider after which all providers in the group can attest to the measure. As with the immunization measure above, providers who do not collect reportable syndromic information on their patients during the reporting period are excluded from reporting this measure.
In summary, the meaningful use objectives are divided into a core set and a menu set. These two sets of objectives can be further divided into those with a target threshold and those without a threshold. Over the past few weeks we have explored the 9 objectives without a threshold (5 core objectives and the 4 on the menu today). In the coming weeks we will take a look at some of the remaining objectives within the CMS EHR incentive program.
Wishing each of you a Happy and Prosperous New Year.
Randy Gertner says
I am struggling with this one a bit. If I submit data on test patient, and the state says they received my email, but their system cannot accept it, do I:
(1) Count this as an exclusion—one exists if the state cannot accept it.
(2) Count this as a positive test—It is just that it is not a successful test.
Thanks,
RG
Terry Ketchersid, Vice President and Medical Officer at HITSG says
Randy, CMS has clarified that in this circumstance you would record an exclusion. Take a look at page 30 of this PDF from the CMS web site:
http://www.cms.gov/EHRIncentivePrograms/Downloads/EP_Attestation_User_Guide.pdf
Randy Gertner says
I think I know the answer to this one, but if I choose both public health measures, and both are excluded, I get credit for 2 out of the 10 menu measures, correct? In that case, I only need to choose 3 more measures for a total of 5 measures in the menu part. Is this line of reasoning correct?
Terry Ketchersid, Vice President and Medical Officer at HITSG says
That is my understanding Randy with the caveat that the provider must select 5 measures which apply to his or her scope of practice.
RG says
Terry,
I am doing some MU work today. This is what I received from my state re: syndrome surveillance (see below). As you can see, the state can accept data, however they will not accept it from a doctors office. My question for you is, would you count this as an exclusion, or would you count this as a “failed test.” This will have some implications when we attest on Jan 1, 2013. I read page 30 on the link you give above again. It says “unless it does not have the capacity to receive the information.” In this case, they do have the capacity but they choose not to accept the data. From our state:
Thank you for your interest in submitting a syndromic surveillance message to Virginia Department of Health to demonstrate meaningful use of your electronic health record system. VDH is not accepting syndromic surveillance messages from physician’s offices during Stage 1 of Meaningful Use, although we are requesting the syndromic surveillance messages from hospitals and urgent care facilities. The implication is that the syndromic surveillance message is not available as a Stage 1 menu option for physician’s offices in Virginia.
Terry Ketchersid, Vice President and Medical Officer at HITSG says
Good question Randy, and one to which I do not have an answer. I would submit the question to CMS. I am surprised at VDH’s response. This objective is clearly intended to apply to any physician whose scope of practice includes reportable diseases. VDH’s resonse is rather counter intuitive to the spirit of this measure which is designed to rapidly assimilate as much information as possible in order to get out in front of epidemics. Let us know if you learn more from CMS.