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Sophie Scheidlinger · May 14, 2015

Make your voice heard: Comment on the new CMS proposed ruling for Meaningful Use public health reporting

The Centers for Medicare and Medicaid Services (CMS) recently released a Notice of Proposed Rulemaking (NPRM) that proposes changes to the current Meaningful Use Program. Overall, CMS has streamlined and simplified attestation requirements and reduced the overall number of objectives for advanced use of EHRs.

These proposed changes may help alleviate your reporting burden and remove measures that have become redundant or have already reached wide-spread adoption. However, one of the proposals in the Modifications to Meaningful Use in 2015 through 2017 NPRM does have concerning implications: the Public Health and Clinical Data Registry (CDR) Reporting Objective.

Public health reporting measures would be consolidated into one objective

For 2015 and beyond, CMS proposes consolidating all of the public health reporting measures into one objective. They are doing away with the core and menu measure structure, and now, five measures comprise this one objective. Eligible providers would need to report on one, two or three of these measures depending on what Meaningful Use stage they are in. The five measures require the provider to be in “active engagement” with the public health agency for:

  • Immunization Registry Reporting
  • Syndromic Surveillance Reporting
  • Case Reporting
  • Public Health Registry Reporting
  • Clinical Data Registry Reporting

The proposed rule states that providers scheduled for Stage 1 in 2015 can complete one measure, while all other providers will need to complete at least two measures in 2015, 2016, and 2017. Starting in Stage 3 in 2018, providers will need to complete three measures.

Three of the proposed measures are potentially unsupported by EHRs, registries, and public health agencies

Case Reporting, Public Health Registry Reporting, and Clinical Data Registry Reporting are brand new measures with no requirement for EHR vendors to build supporting functionality until 2018. Moreover, many immunization registries and public health agencies interested in syndromic surveillance data submission are not prepared to accept files in the format that EHR vendors were required to build and transmit them.

Practice Fusion knows the struggle providers face today with submitting immunizations to their state registries. Expecting every provider to complete this successfully this year is challenging enough without requiring that providers also report syndromic data or attempt to engage with brand new measures unsupported by their vendors, registries, or public health agencies. If the proposed measure is not amended in the final rule, we suspect providers may not be able to meet Meaningful Use as a result.

If the proposed measure is not amended, providers may not be able to meet Meaningful Use

CMS is seeking specific feedback on these proposed rules in order to determine the content of the final rules which determine what will be required of eligible providers. Indicating your support of a change is encouraged, as is specifically explaining why you may not support a change, and what alternative solutions you might suggest. has also provided tips for submitting an effective comment.

Comment on Meaningful Use in 2015-2017 proposed changes

View the Modification to Meaningful Use in 2015-2017 proposed rule, then click the green button to submit a formal comment.

Comment now »

Keep in mind that these comments will be public, and are due by June 15, 2015 11:59PM ET. You can also submit comments on the proposed modifications to the Stage 3 proposed rule.