Frequently Asked Questions

While CMS and ONC are the federal agencies responsible for administering Meaningful Use, several other stakeholder organizations provide information.

The following are links to web pages on Meaningful Use:

• Office of the National Coordinator for Health Information Technology (ONC)
• Centers for Medicare and Medicaid Services (CMS)
• Association of State and Territorial Health Officials (ASTHO)
• National Association of City and County Health Officials (NACCHO)
• Healthcare Information and Management Systems Society (HIMSS)
• International Society for Disease Surveillance (ISDS)
• Indian Health Service (IHS)

The Centers for Disease Control and Prevention (CDC) is engaged in EHR policy decisions to improve care for individuals and provide leadership to leverage Meaningful Use for public health. Currently, we are collaborating with and providing input to ONC and CMS for consideration of public health priorities within Meaningful Use now and in the future. CDC incorporates partner feedback in our input through our engagement with national public health organizations (e.g., ASTHO, NACCHO, APHL, etc.). In an effort to educate stakeholders, CDC is also working to provide consolidated information to its programs and partners as well as through forums to the general public through:

• http://www.cdc.gov/EHRmeaningfuluse/
• Quarterly newsletters
• Partner calls

Discussion forums will be used for future dialogue and engagement with CDC’s current and future partners. For further information please contact: meaningfuluse@cdc.gov

The CDC collaborates with its federal partners (CMS and ONC) on HIT policy development and in defining Stages 1-3 criteria for Meaningful Use. Additionally, CDC works with other national partners such as Joint Public Health Informatics Taskforce (JPHIT), Association of State and Territorial Health Officials (ASTHO), and International Society for Disease Surveillance (ISDS) to develop policies, guidelines, and methods, and to promote a shared vision for how public health interacts with the healthcare community. CDC works with Health Level 7 (HL7), Integrating the Healthcare Enterprise (IHE) and other standard development organizations on development and implementation of interoperable messaging and vocabulary standards and implementation guides.

For example, CDC advocated for population health at the following forums in 2010:

• HHS HIT Policy Committee Meaningful Use Workgroup Population Health Hearing
• NACCHO PHI Task Force
• JPHIT “Meaningful Use” Readiness Summit
• HHS HIT Standards Committee Clinical Operations Workgroup Vocabulary Task Force Hearing
• JPHIT Summit 2.0
• ONC Plenary Session

Within the CDC, an EHR Meaningful Use Advisory Group (MUAG) was formed to provide strategic planning to ensure that the agency launches a comprehensive and coordinated approach to support development of state and local health department capacity to accept electronic information from EHRs, including syndromic surveillance, immunization registries, and electronic laboratory reporting between laboratories and the health departments. The MUAG is co-sponsored by the Office of Surveillance, Epidemiology and Laboratory Services (OSELS) and the Office of State, Tribal, Local and Territorial Support (OSTLTS).

Specifically the objectives of the MUAG include:

• Develop CDC strategies by :
  • Addressing CDC Director’s priorities (http://www.cdc.gov/about/winnablebattles.htm)
  • Supporting the use of health information technology to improve the quality of health care, reducing health disparities, and improving public health
  • Increasing coordination with community resources
  • Coordinating state and community resources to support national and state bi-directional information exchange
• Serve as the CDC point of contact for Meaningful Use
• Guide communication and coordination across the agency

Meaningful Use Certification means having technology certified by an ATCB against NIST procedures:
http://healthcare.nist.gov/use_testing/effective_requirements.html

Once a technology is certified a hospital begins testing with the public health agency.  Public health will confirm receipt and begin the content validatation process on messages they receive from hospitals.  Hospitals can then attest to successful completion of this reportable laboratory results objective.

No, the standards and certification rule is silent on transport methods and routing of messages to public health.  The focus of the rule is on the capability of the EHR to produce a structured message that has the capability to contain standardized value sets. Routing and transport are not certified under the rule.

From the CMS Website:
Medicare Eligible Hospitals

Eligible hospitals and critical access hospitals (CAHs) will qualify for incentive payments under the Medicare EHR Incentive Program if they successfully demonstrate meaningful use of certified EHR technology.

Eligible hospitals and CAHs that adopt and successfully demonstrate meaningful use of certified EHR technology can begin receiving incentive payments for any year from federal fiscal year (FY) 2011 to FY 2015.Incentive payments to eligible hospitals and CAHs may begin as early as 2011 and are based on a number of factors, beginning with a $2 million base payment.The law defines a payment year for eligible hospitals and CAHs in terms of federal fiscal year (FY) beginning with FY 2011. However, a hospital does not have to begin receiving incentive payments in FY 2011.Hospitals can begin receiving EHR incentive payments in any year from FY 2011 to FY 2015, but payments will decrease for hospitals that start receiving payments in 2014 and later.Hospitals that do not successfully demonstrate meaningful use of certified EHR technology beginning in FY 2015 will be subject to payment adjustments.

Medicaid Eligible Hospitals

Eligible hospitals will qualify for incentive payments if they adopt, implement, upgrade or demonstrate meaningful use of certified EHR technology during the first participation year or successfully demonstrate meaningful use of certified EHR technology in subsequent participation years.

Medicaid hospitals that qualify for EHR incentive payments may begin receiving incentive payments in any year from FY 2011 to FY 2016.

While the law defines a payment year in terms of a federal fiscal year (FY) beginning with FY 2011, a hospital does not have to begin receiving incentive payments in FY 2011. http://www.cms.gov/EHRIncentivePrograms/95_FAQ.asp#TopOfPage

CMS and ONC will begin developing Stage 2 rules on incentive program and standards in Summer 2011 released for public comment by early winter of 2012.  This will include standards, objectives and clinical quality measures included in Stage 2.

The result will be an interim final rule based on feedback from the HIT Policy and Standards Committees, comment on proposed meaningful use objectives solicited by the policy committee and input from federal agencies.  The interim final rule to be released in 2012 will have a 90 day comment period.   State, Local, Tribal and Territorial public health agencies will have the opportunity to comment during that 90 day period.  By law, all comments received during this comment period must be considered by the federal agencies developing the final rule. Additionally, there are certain times when HHS Advisory Committees ask for presentations and testimony from public health agencies or public health agency staff are asked to serve on committee workgroups.

The information on incentives for Eligible professionals who comply with the meaningful use of electronic health records can be from on the CMS website: http://questions.cms.hhs.gov/app/answers/detail/a_id/9055/kw/incentive%20payment

Meaningful use impacts public health by: Meaningful Use activities will improve the collaboration between clinical and public health care at local and state levels through:Implementation of electronic reporting to PH (immunization, laboratory and syndromic surveillance)Improvement of a patient-centric preventive care (preventive care-oriented quality care measures) 2. MU rules bring attention to the readiness of State Public Health agencies for a “birectional communication” with clinical care providers 3.  MU will bring into play, the development of standardized data elements and messaging implementation guides (data exchange) for MU Public Health measures. 

The stage 1 of meaningful use has three public health objectives, which require capability to submit electronic data to public health agencies for 1)immunization registries, 2) reportable lab results and 3) syndromic surveillance- in accordance with the applicable law and practice.

Language from final rule:
Policy Priority: improve population and public health

1. "Capability to submit electronic data to immunization registries or Immunization Information Systems and actual submission in accordance with applicable law and practice.
2. "Capability to submit electronic data on reportable (as required by state or local law) lab results to public health agencies and actual submission in accordance with applicable law and practice."
3. "Capability to submit electronic syndromic surveillance data to public health agencies and actual submission in accordance with applicable law and practice."
http://www.federalregister.gov/articles/2010/07/28/2010-17207/medicare-and-medicaid-programs-electronic-health-record-incentive-program

Not unless the large laboratory has a certified laboratory information management systems (LIMS)/Laboratory Infrastructure and Support (LIS) system that isa certified module of the hospital’s EHR.

A lab vendor should contact an ONC-Authorized Testing and Certification Body (ATCB).  The list ATCB is found at:

http://healthit.hhs.gov/portal/server.pt?open=512&mode=2&objID=3120

Requirements for certifying a module can be found at:

http://healthcare.nist.gov/docs/170.306.g_LabstoPH_v1.1.pdf

The Office of the National Coordinator for Health Information Technology (ONC) lists the vendors and products that have been certified for meaningful use by one of the recognized certifying bodies.  For more information on which EHRs have been certified, visit:
http://onc-chpl.force.com/ehrcert

If the laboratory's LIS or LIMS is part of a certified modular EHR, then results sent from the LIS/LIMS qualify.

For the purpose of meaningful use, an EHR is made up of all the components that can satisfy the requirements of meaningful use. That is, it can meet all the objectives specified in the standards and certification rule dated July 28, 2010.  In the case of ELR, laboratory information system vendors could have their module that reports laboratory results certified by one of the certifying bodies.  For more information on how vendors get their EHRs and modules certified, visit ONC’s standards and certification rule:   http://healthit.hhs.gov/portal/server.pt/community/healthit_hhs_gov__regulations_
and_guidance/1496
and ONC’s frequently asked questions about EHR modules (http://healthit.hhs.gov/portal/server.pt/community/onc_regulations_faqs/3163).

From the CMS FAQ site:

EPs are required to report on a total of 5 meaningful use objectives from the menu set. When selecting five objectives from the menu set, EPs must choose at least one option from the public health menu set. If an EP is able to meet the measure of one of the public health menu objectives but can be excluded from the other, the EP should select and report on the public health menu objective they are able to meet. If an EP can be excluded from both public health menu objectives, the EP should claim an exclusion from only one public health objective and report on four additional menu objectives from outside the public health menu set. We encourage EPs to select menu objectives that are relevant to their scope of practice, and claim an exclusion for a menu objective only in cases where there are no remaining menu objectives for which they qualify or if there are no remaining menu objectives that are relevant to their scope of practice. For example, we hope that EPs will report on 5 measures, if there are 5 measures that are relevant to their scope of practice and for which they can report data, even if they qualify for exclusions in the other objectives. Please note that EPs must have complete certified EHR technology (or a complete set of certified EHR modules) capable of supporting all of the core and menu set objectives, including any objectives for which the EP can claim an exclusion and menu set objectives the EP does not select. http://questions.cms.hhs.gov/app/answers/detail/a_id/10532/kw/public%20health

Two public health message validation tools are available from CDC:

A national-level (centrally hosted by CDC) tool: Message Quality Framework (MQF).  For detailed listing of message specifications supported by MQF refer to the MQF left navigation panel link Supported Specifications in the MQF website https://phinmqf.cdc.gov

A state-level (locally hosted) tool: Message Subscription Service (MSS). http://www.cdc.gov/phin/library/phin_fact_sheets/111759_NMS_NEDSS.pdf

Automated testing tools ensure messages adhere to standards defined in the messaging guides by: validating the structure of the message, validating that the messages are following the business rules defined for the message, and verifying that the vocabulary defined for the message is utilized.

Other non-CDC public health testing tools are available such as Rhapsody and Message Workbench.  MQF provides the capability for implementers, who have interface engines such as Rhapsody, Mirth, Cloverleaf/Quovadx, etc, to download conformance profiles developed based on the message specifications. The formats available for download are XML and Rhapsody S3D. This conformance profile is what the MQF application uses to perform the validation of the messages. Profiles can be downloaded from the following site: https://phinmqf.cdc.gov/DownLoad.aspx

CMS has posted a timeline for meaningful use implementation.  It can be found at the following address: http://www.cms.gov/EHRIncentivePrograms/01_Overview.asp#BOOKMARK3

Two websites are recommended :

1. http://healthit.hhs.gov
2. http://www.cms.gov/ehrincentiveprograms/

The provider would need to switch to the reportable laboratory results public health objective. Eligible providers and hospitals (EP/EH) are required to achieve at least one of the public health objectives. EP/EH must choose a public health objective their jurisdictional public health agency is capable of receiving.

It only applies to eligible hospitals in Stage 1. Stage 2 and 3 are currently being defined.

There are many variations to whether or not an outpatient clinic would be considered an eligible provider. For answers to these variations, please visit the Centers for Medicare & Medicaid Services Meaningful Use FAQs website athttps://questions.cms.hhs.gov/app/answers/list/p/21,26,1139

To find most of the variations to this question and subsequent answers, enter into the advanced search box.

An EHR or a module that supports electronic laboratory reporting must have the capability to construct the HL7 2.5.1 message and is capable of storing, retrieving and sending LOINC codes according to the HL7 2.5.1 messaging guide to become certified for meaningful use by the ATCB. The public health agency would specify which fields are required as it begins the testing and validation process with the public health agency.