Member Update
March 1, 2016
MU Public Heath Reporting Objective
New Guidance from CMS

Prior to February 25, CMS guidance stated that eligible professionals (EPs) had to either be actively engaged in, or submit intent to engage in, 2 public health registries by February 29, for the 2016 program year. Their guidance at that time was that the alternate exclusions did not apply for 2016. We sent a Connections Member Update to you on the 23rd to remind you about this deadline.

On February 25, CMS released new guidance allowing EPs to use alternate exclusions for 2016 reporting.

According to the new guidance, providers can claim alternate exclusions for syndromic surveillance reporting and specialized registry reporting in 2016. Excerpts from the CMS FAQ follow.
"We will allow providers to claim an alternate exclusion for the Public Health Reporting measure(s) which might require the acquisition of additional technologies the providers did not previously have or did not previously intend to include in their activities for meaningful use". For the public health reporting objective in 2016, EPs may "claim an Alternate Exclusion for Measure 2 and Measure 3 (Syndromic Surveillance and Specialized Registry Reporting)."

Trish Harkness, Synōvim Healthcare Solution's Senior Information Systems Security Services Consultant, recommends the following.
  • KDHE does not accept syndromic surveillance from EPs, so providers should attest "no" to the alternate exclusion and "yes" to the (standard) exclusion so that they will only attest to an alternate exclusion for the specialized registry. Since immunizations were originally required by MU Stage 2, providers may not claim the alternate exclusion for the immunization registry; they can, of course, claim the (standard) exclusion for immunizations if they do not provide them.

The question is asked in FAQ 14397, "What if the software is potentially available but there is a significant cost to connect to the interface?" Trish's interpretation is that CMS is willing to allow providers to claim the alternate exclusion even if a registry option is available.
Registry Readiness FAQ

FAQ 14393 indicates that providers can register their notice of intent after the first 60 days of the reporting period if the "registry declares readiness at any point in the calendar year after the initial 60 days"; however, "a provider who could report to that registry may still exclude for that calendar year if they had already planned to exclude based on the registry not being ready to allow for registrations of intent within the first 60 days of the reporting period".
Contact the HCCN Grant Project Team
Feel free to contact any member of the KAMU HCCN Grant Project Team below.

Terri Kennedytkennedy@kspca.org785-233-8483
Susan Woodswood@kspca.org785-233-8483
Amy Byeramy.byer@synovim.org316-737-9743
Trish Harknesstrish.harkness@synovim.org620-874-8034
Health Center Connections is a health center controlled network organized and supported by KAMU. Current funding for Connections is through Health Resources and Services Administration (HRSA) HCCN Funding Opportunity HRSA-13-237.