How to Meet CMS' Data-Transmission Requirements

In Stage 2, physicians must "provide a summary of care record for more than 50 percent of transitions of care and referrals." While that isn't too difficult to do, CMS has added a kicker: More than 10 percent of transitions of care must be electronically transmitted using certified EHR technology (CEHRT) to a recipient, or where the recipient receives the summary of care record via exchange facilitated by an organization that is a Nationwide Health Information Network (NwHIN) Exchange participant, or in a manner that is consistent with the governance mechanism ONC establishes for the nationwide health information network.

Also as part of the requirement, an eligible provider (EP) must satisfy one of the two following criteria:

1. Conduct one or more successful electronic exchanges of a summary of care document with a recipient who has EHR technology that was developed by a different EHR technology developer than the sender's EHR; or

2. Conduct one or more successful tests with the CMS-designated test EHR during the EHR reporting period.

While the onus is on vendors to bring their technology up to speed so that it meets CMS' "meaningful use" data specifications, providers will bear the responsibility of choosing how to meet this objective, which is much more challenging than the Stage 1 objective it stems from.

"In Stage 1, providers had to perform at least one test of certified EHR technology's capacity to electronically exchange key clinical information," observes Jeff Loughlin, project director with the Massachusetts eHealth Collaborative, which oversees the regional extension center (REC) for New Hampshire. "There were several ways to complete this, but at the lowest level, an EP could create a summary of care record using test patient data, then send it out over unsecure e-mail as an attachment. Although this may have met the standards, it did not necessarily meet the spirit of the objective to really engage providers in the exchange of electronic information."

But while CMS has made the data-exchange care-transition requirement for Stage 2 much harder, fortunately, there is more than one way for physicians to meet Stage 2 requirements, says healthcare regulatory expert Jason Fortin, senior adviser, for Naperville, Ill.-based Impact Advisors.

Should physicians opt to send data via an NwHIN Exchange participant, or health information exchange (HIE), they may choose to join an existing HIE from a list of certified participants at www.healthewayinc.org (as of November 6, there are no ONC-established governance mechanisms). One benefit of joining an established HIE is to exchange data with multiple healthcare providers in your community quickly and easily, says Fortin.

"It is an alternative, but remember that EPs will have to have EHRs that are capable of the push transmission."

However, Fortin points out, many HIEs are not yet as sophisticated as physicians would like them to be, not to mention cost money to join.

"There's no shortage of [HIEs]," says Fortin. "But a lot of HIEs are still in the planning stages, and don't translate data well."

That's why Austin, Texas-based family physician Kevin Spencer plans to meet the requirement another way: By interfacing with the EHRs of his top referral sources, and partnering with a local hospital.

"We're looking at our database of top three referral sources and building an interface to share data," says Spencer, adding that his vendor, Greenway Medical Technologies, will be creating the technology that allows him to do this. "We can't interface with everyone, it's too expensive. But it's easier than waiting for a standardized HIE [that we like]."

Fortin suggests practices start by making sure they have an established connection with top referral sources - and that they can receive data. This is important because many of a practice's healthcare partners, such as long-term-care facilities, which aren't required to participate in the meaningful use program, may not be able to receive structured data via the transmission standards specified by the ONC.