What a difference a couple of words make.

CMS FAQ on Public Health Measures (#12985) – October 2015

EPs scheduled to be in Stage 2: Must attest to at least 2 measures from the Public Health Reporting Objective Measures 1-3

May claim an Alternate Exclusion for Measure 2 or Measure 3 (Syndromic Surveillance Measure or Specialized Registry Reporting Measure). 

NOTE THE WORDING SAYS “MEASURE 2 OR MEASURE 3” NOT MEASURE 2 AND MEASURE 3 – This implies that the alternate exclusion could only be used one time, on Measure 2 or Measure 3 but not both.

CMS FAQ on Public Health Measures (#12985) – Current Version

(You can view the current CMS FAQ on Public Health Measures here.)

EPs scheduled to be in Stage 2: Must attest to at least 2 measures from the Public Health Reporting Objective Measures 1-3

May claim an Alternate Exclusion for Measure 2 or Measure 3 (Syndromic Surveillance Measure or Specialized Registry Reporting Measure) or both

* NOTE THE WORDS “OR BOTH”

What is the difference? In the current version, CMS now confirms that the alternate exclusion can be claimed for both Syndromic Surveillance and for Specialized Registries; not one or the other. This means that if the provider did not originally intend to attest to Syndromic Surveillance and for Specialized Registries, they simply claim the alternate exclusion when attesting for both measures. No need to engage with those registries — if appropriate, just claim the alternate exclusion.

Note: There are 3 Public Health Registries to consider and the alternate exclusions do not apply to the Immunization Registry requirement. Providers must either meet a standard exclusion, or at a minimum, actively engage with an Immunization Registry.

This change in the FAQ was not widely publicized by CMS but it does greatly simplify the ability for providers to successfully attest to the Public Health Objective.

You can read the 2015 EHR Incentive Programs: Alternate Exclusions & Specifications from CMS here.