In the 2015 EHR Incentive Program’s Final Rule, CMS stated that they did not intend for providers to be inadvertently penalized for EHR system changes related to reporting certain provisions of that regulation including parts of the public health objective. We have for a while believed that eventually CMS would clarify their position on this issue especially as it relates to reporting to syndromic surveillance and specialized registries.
Per CMS: “… in order that providers are not held accountable to obtain and implement new or additional systems, we will allow providers to claim an alternate exclusion from certain public health reporting measures in 2016 if they did not previously intend to report to the Stage 2 menu measure.”
LIST OF MEASURES FOR EPs WHICH WOULD ALLOW AN ALTERNATE EXCLUSION:
Public Health Reporting measure 2 – syndromic surveillance
Public Health Reporting measure 3 – specialized registry
Since the onset of Stage 2, we have been campaigning for a relaxation of the syndromic surveillance and specialized registries requirement (see our blogs, An Important Meaningful Use Update and Stage 2 Meaningful Use Changes the Format for Exchanging patient Health Records).
As we stated several times, the healthcare ecosystem is just not ready for this type of interoperability challenge. The question we all must keep asking ourselves is: Why is CMS always late to the party? Their rulemaking is chaotic and unfair to the provider community. We are elated to report that Meaningful Use in 2016 just got easier and more importantly, fairer. We feel bad for the providers that already spent their hard earned dollars on enrolling in registries they never needed to pay for. Lesson learned; we all must prepare for government programs, but I advocate proceeding as carefully as possible until the Meaningful Use and MACRA programs reach a steady state.