By Jason McCormick
Even though the attestation period for 2015 Meaningful Use reporting will not be complete for the next several days, many orthopaedic practices are already looking ahead to determine which program objectives will be difficult to meet in 2016. It should come as no surprise that most orthopaedic providers have not been as accepting of the Meaningful Use program as primary care providers. Opportunities to meet objective requirements for CPOE of laboratory orders or medication reconciliation for transitions of care have not been abundant, but have proven to be costly and time-consuming for practice staff. But over the course of the program, no objective or measure has caused more confusion than the Public Health Reporting measures.
In what only can be described as the most confusing Meaningful Use requirement to date, Objective 10 of CMS’s Modified Meaningful Use requires eligible professionals to meet the requirements of, or the exclusion criteria for, three different measures related to reporting data to registries. Measure 1 requires eligible providers to submit immunization data to state-sponsored registries, Measure 2 requires submission of syndromic surveillance data to public health agencies, and Measure 3 requires participation in a specialized registry. Much of the confusion comes from the wording of the measures that states that eligible providers must be “actively engaged” with a public health agency, or other specialized registry, to submit electronic public health data. What the Objective does not state is how orthopaedic providers and practices are supposed to comply with this requirement, which is one of many that reinforces the viewpoint that Meaningful Use is a program that is geared towards primary care providers, and not specialists. Exclusion criteria are available for each measure, but the wording of Measure 3’s exclusion criteria leaves you with more questions than answers. While searching for insight into how to ensure our providers are in compliance, or at least demonstrating due diligence to try to comply, many orthopaedic practice managers are unsure of what course of action should be taken. They are willing to talk to their EHR vendors, their practice consultants, even their ListServ colleagues, in order to find some kind of answer or insight into how to handle the requirement. It is just at the moment that the practice is about to sign a contract with an organization that promises they are the answer that guidance is provided in one of the most unexpected places – CMS FAQs!
While it may seem like the appropriate place to find answers, the FAQs have not historically given practice managers the insight that is offered by CMS FAQ #13657. Assuming that the practice is already aware of their responsibility to report immunization or syndromic surveillance data to a public health agency, FAQ #13657 addresses the requirements for identifying specialized registries available to providers, or demonstrating due diligence, and the criteria for claiming an exclusion for Measure 3 of the Objective. The task at hand is to not over-think the language that CMS included in the FAQ. Here’s a simple blue-print for how you can determine if there are any specialized registries available to you, or if you will be able to claim an exclusion and defend your determination.
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