PUBLIC HEALTH ADVISORY CONCERNING FENTANYL AND FENTANYL-LACED SUBSTANCES

Public Health Reporting using Certified Electronic Health Record Technology (CEHRT)

The Tennessee Department of Health collects health information to prevent and contain outbreaks, analyze population health trends, track immunization rates, track infectious diseases, and educate and promote healthy choices for the people of Tennessee. Public health reporting incentives provided by Medicaid and Medicare Electronic Health Record (EHR) Incentive Program (aka Meaningful Use) and the Medicare Merit-based Incentive Payment System (MIPS) programs are prompting increased partnerships between TDH and health care providers capable exchanging public health information electronically.

Because of increased EHR adoption, public health reporting requirements can be more rapidly and easily reported to TDH. The process to exchange data begins when a potential trading partner registers with TDH expressing their intent to exchange data electronically using the Trading Partner Registration (TPR) system. Training is provided to help potential trading partners register – click here to see available schedule. 

Meaningful Use Summary

The American Recovery and Reinvestment Act of 2009 (ARRA) (Pub. L. 111–5) amended Titles XVIII and XIX of the Social Security Act (the Act) to authorize incentive payments to Eligible Professionals (EPs), Eligible Hospitals (EHs), Critical Access Hospitals (CAHs) and Medicare Advantage (MA) organizations to promote the adoption and meaningful use of Certified Electronic Health Record Technology (CEHRT).

Meaningful Use (MU) is using certified EHR technology to
  • Improve quality, safety, efficiency and reduce health disparities
  • Engage patients and families in their healthcare
  • Improve care coordination
  • Improve population and public health

The Centers for Medicare & Medicaid Services (CMS) recently published a final rule that specifies criteria that eligible professionals (EPs), eligible hospitals (EHs) and critical access hospitals (CAHs) must meet to participate in the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs.

doctor examining a brain cat scan on a digital tablet

The new requirements of the EHR Incentive Programs expand meaningful use of certified EHR technology to promote health information exchange and improved patient outcomes. The rule also includes changes to the structure of the EHR Incentive Programs to improve efficiency, effectiveness and flexibility.

CMS evaluated the current programs and identified areas where modifications could be made to align with the long-term vision and goals for Stage 3. CMS restructured the objectives and measures of the EHR Incentive Programs in 2015 through 2017 to align with Stage 3, and modified “patient action” measures in Stage 2 objectives.  These changes recognize the progress providers have made and realign with long term goals. The new rules will require all providers attest to a single set of objectives and measures beginning with an EHR reporting period in 2015 instead of waiting until Stage 3 in 2018.

Objectives and Measures

  • All providers required to attest to single set of objectives and measures, replacing core and menu objectives structure of previous stages.
  • Accommodations to assist providers already working on meaningful use in 2015, including:
    • Retaining different specifications between Stage 1 and Stage 2
    • Allowing special exclusions for certain objectives/measures for those previously scheduled to participate in Stage 1 for EHR reporting period in 2015

For the EHR Incentive Programs in 2015 through 2017, major provisions include:

  • 10 objectives for eligible professionals including one public health reporting objective, down from 18 total objectives in prior stages.
  • 9 objectives for eligible hospitals and critical access hospitals (CAHs) including one public health reporting objective, down from 20 total objectives in prior stages.
  • Clinical Quality Measures (CQM) reporting for both eligible professionals (EPs) and eligible hospitals/CAHs remains as previously finalized.

Stage 3 Public Health Reporting Requirements

For Stage 3 of the EHR Incentive Programs in 2017 and subsequent years, major provisions include:

  • 8 objectives for eligible professionals, eligible hospitals, and CAHs:  In Stage 3, more than 60 percent of the proposed measures require interoperability, up from 33 percent in Stage 2.
  • Public health reporting with flexible options for measure selection.
  • CQM reporting aligned with the CMS quality reporting programs.
  • Finalize the use of application program interfaces (APIs) that enable the development of new functionalities to build bridges across systems and provide increased data access. This will help patients have unprecedented access to their own health records, empowering individuals to make key health decisions.

TDH Declaration of Readiness for Public Health Reporting 

As of July 1, 2017, TDH is declaring readiness for the following Public Health Reporting objectives and measures. MU EHR Incentive Program and MIPS/Advancing Care Information providers should check here periodically for updates to TDH’s Public Declaration of Readiness to receive data from Certified Electronic Health Record Technology (CEHRT).

Requirements and references are listed for your convenience. 

Electronic Case Reporting (eCR)

Electronic Case Reporting (eCR) is the automated generation and transmission of case reports from an electronic health record (EHR) to the public health agency’s disease surveillance system for review and action. eCR will allow healthcare providers the opportunity to report suspected cases to TDH for further investigation using an electronic health record (EHR) system rather than manually reporting on paper and waiting on lab test results to confirm a suspected case. The eCR will capture critical clinical and demographic patient data from Certified Electronic Health Record Technology (CEHRT) not otherwise included in laboratory reports. Utilizing eCR will reduce the burdensome paper-based and labor-intensive administrative process reporters face in reporting and responding to public health’s requests for additional information.

Electronic Case Reporting Measure

TDH will declare readiness for eCR in January 2018 under the Public Health Reporting Objective and begin accepting eCR in July of 2018 from pilot partners. Currently, TDH is actively developing requirements and documentation to begin pilot testing with selected trading partners. Eligible providers and eligible hospitals interested in eCR pilot testing in 2018 can email us directly at CEDS.Informatics@tn.gov for more information.

Electronic Lab Reporting (ELR)

EHR Incentive Programs support the adoption and meaningful use of certified EHR technology to allow providers to exchange public health information electronically. TDH is currently accepting electronic reportable laboratory results from eligible hospitals (EHs) and eligible clinical access hospitals (CAH) only. 


Electronic Reportable Laboratory Result Reporting Measure

Modified Stage 2

Stage 3 (2017 Optional)

2014 CEHRT

2015 CEHRT

HL7 Version 2.5.1 Implementation Guide: Electronic Laboratory Reporting to Public Health, Release 1 (US Realm), with Errata and Clarifications  

HL7 Version 2.5.1 Implementation Guide: Electronic Laboratory Reporting to Public Health, Release 1 (US Realm), with Errata and Clarifications

In order to satisfy TDH’s requirements for MU Public Health Reporting all potential trading partners must first register their intent to exchange data: Trading Partner Registration (TPR)


The MU EHR Incentive Program requires EHs and CAHs to be in active engagement with public health to send electronic reportable laboratory results from CEHRT, except where prohibited, and in accordance with applicable law and practice.

Note: The time until live data exchange varies and depends upon the quality and speed of data exchange testing.

Send inquiries to CEDS.Informatics@tn.gov

Syndromic Surveillance Reporting

EHR Incentive Programs support the adoption and meaningful use of certified EHR technology to allow providers to exchange public health information electronically. TDH is currently accepting syndromic surveillance data from Eligible Hospitals (EHs) with an emergency department only.


Syndromic Surveillance Measure

Modified Stage 2

Stage 3 (2017 Optional)

2014 CEHRT

2015 CEHRT

HL7 2.5.1 PHIN Messaging Guide for Syndromic Surveillance: Hospitals with an Emergency Department, Release 1.1 (August 2012)

HL7 2.5.1 PHIN Messaging Guide for Syndromic Surveillance: Emergency Department, Urgent Care, Ambulatory Care and Inpatient Settings, Release 2.0

In order to satisfy TDH’s requirements for MU Public Health Reporting all potential trading partners must first register their intent to exchange data: Trading Partner Registration (TPR)


The MU EHR Incentive Program requires EHs to be in active engagement with public health to submit syndromic surveillance data from CEHRT, except where prohibited, and in accordance with applicable law and practice.

Note: The time until live data exchange varies and depends upon the quality and speed of data exchange testing. At this time, TDH is not accepting syndromic surveillance data from any eligible professionals.

Send inquiries to CEDS.Informatics@tn.gov.

Tennessee Immunization Information System (TennIIS)

EHR Incentive Programs support the adoption and meaningful use of certified EHR technology to allow providers to exchange public health information electronically. TDH is currently accepting immunization data from EPs, EHs, and CAHs. 


Immunization Registry Reporting Measure

Modified Stage 2

Stage 3 (2017 Optional)

2014 CEHRT

2015 CEHRT

HL7 Version 2.5.1: Implementation Guide for Immunization Messaging, Release 1.4

 

HL7 Version 2.5.1: Implementation Guide for Immunization Messaging, Release 1.5 (October 2014) and Addendum (July 2015). Includes the ability to respond to bidirectional queries and the capacity to receive NDC codes.

In order to satisfy TDH’s requirements for MU Public Health Reporting all potential trading partners must first register their intent to exchange data: Trading Partner Registration (TPR)


The MU EHR Incentive Program and the MIPS Advancing Care Information program require EPs, ECs, EHs, and CAHs to be in active engagement with public health to submit immunization data from CEHRT except where prohibited and in accordance with applicable law and practice.

Note: The time until live data exchange varies and depends upon the quality and speed of data exchange testing.

Send inquiries to TennIIS.MU@tn.gov. Your points of contact will be Nicole Haas or Sarah Rudd. 

Tennessee Cancer Registry (TCR)

EHR Incentive Programs support the adoption and meaningful use of certified EHR technology to allow providers to exchange public health information electronically. TDH is currently accepting immunization data from EPs, EHs, and CAHs.


Specialized Registry Reporting Measure

Modified Stage 2 (Specialized Registry Reporting)

Stage 3 (2017 Optional)

2014 CEHRT

2015 CEHRT

Implementation Guide for Ambulatory Healthcare Provider Reporting to Central Cancer Registries, HL7 Clinical Document Architecture (CDA), (August 2012)

Cancer Case Reporting is a part of the Public Health Registry Reporting measure in stage 3 for EPs; however TDH is not participating in Cancer Case Reporting for optional Stage 3 in 2017.

In order to satisfy TDH’s requirements for MU Public Health Reporting all potential trading partners must first register their intent to exchange data: Trading Partner Registration (TPR)


The MU EHR Incentive Program requires EPs to be in active engagement with public health to submit data to a specialized registry from CEHRT except where prohibited and in accordance with applicable law and practice.

Note: The time until live data exchange varies and depends upon the quality and speed of data exchange testing.

Send inquiries to TNCancer.Registry@tn.gov.


TDH will declare readiness for eCR in January 2018 under the Public Health Reporting Objective and begin accepting eCR in July of 2018 from pilot partners. Currently, TDH is actively developing requirements and documentation to begin pilot testing with selected trading partners. Eligible providers and eligible hospitals interested in eCR pilot testing in 2018 can email us directly at CEDS.Informatics@tn.gov for more information.​

TDH also continues to onboard trading partners capable of implementing bidirectional immunization reporting requirements for HL7 2.5.1 following the 1.5 implementation guide now. For questions related to Immunization Registry Reporting, contact TennIIS.MU@tn.gov.

MU EHR Incentive Program and MIPS/Advancing Care Information providers should check here periodically for updates to TDH’s Public Declaration of Readiness to receive data from Certified Electronic Health Record Technology (CEHRT). For questions related to the TDH Declaration of Readiness, contact the TDH Meaningful Use Coordinator at (615) 253-8945 or MU.Health@tn.gov.  


TDH Public Health Reporting Procedures

In the MU EHR Incentive Program’s for 2015 through 2017 proposed rule 80 FR20366, CMS highlighted their intention to align with the Stage 3 proposed rule and remove the term “ongoing submission” and replace it with an "active engagement" requirement. Active engagement may be demonstrated by any of the following options:

Active Engagement Option 1 – Complete Registration of Intent to Submit Data

The EP, EH or CAH registered to submit data with the PHA or, where applicable, the CDR to which the information is being submitted; registration was completed within 60 days after the start of the EHR reporting period; and the EP, eligible hospital, or CAH is awaiting an invitation from the PHA or CDR to begin testing and validation.

In Tennessee, the onboarding process to exchange data with the Tennessee Department of Health (TDH) begins when a potential trading partner registers with TDH expressing their intent to exchange data electronically.

The Trading Partner Registration (TPR) system allows potential trading partners to register for Immunization Messaging (new registrations), Cancer Case Reporting, Electronic Laboratory Reporting (ELR) and Syndromic Surveillance Messaging (Eligible Hospitals w/Emergency Room) in one location. TPR provides documentation that can be utilized for Meaningful Use attestation and allows users to view their progress from end to end through the use of milestone letters documenting on-boarding progress. Click here to download the TPR Worksheet.

Also displayed within the TPR organizational profiles are requests for actions. TDH expects the responses of potential trading partners to requests for actions to be applicable with moving the trading partner to a production status. TDH reserves the right to disengage in onboarding activates with any trading partner, at any time, due to consistent problems associated with reporting requirements, and file specifications in accordance published national standards. The trading partner’s active engagement status will be provided in the TPR system under the Interface Details tab.

Click here to see a listing of training dates and times. To receive the TPR webinar details, you must complete the registration form found at http://tn.gov/health/calendar/meaningful-use. If the requested date/time is available, you will receive an email invitation with the conference phone number and webinar link. If you do not receive an email within 2 business days send an email to mu.health@tn.gov.

Active Engagement Option 2 –Testing and Validation

The EP, EH or CAH is in the process of testing and validating of the electronic submission of data. Providers must respond to requests from the PHA or, where applicable, the CDR within 30 days; failure to respond twice within an EHR reporting period would result in that provider not meeting the measure.

The TDH interfaces will invite the EPs, EHs or CAHs to begin submitting test messages. TDH staff will validate the messages and provide information needed to correct errors or omissions. The testing procedures and requirements will vary between TDH interfaces and will depend upon which stage of the Meaningful Use process is being completed. The testing and validation process will continue until the onboarding team states the messages have met the requirements. The trading partner’s active engagement status will be provided in the TPR system under the Interface Details tab.

Active Engagement Option 3 – Production (Ongoing Electronic Submission)

The EP, eligible hospital, or CAH has completed testing and validation of the electronic submission and is electronically submitting production data to the PHA or CDR.

Appropriate TDH program staff will indicate that testing has been successfully completed and data is being sent to the TDH production system. TDH may communicate with those reporting electronically about data quality. The trading partner’s active engagement status will be provided in the TPR system under the Interface Details tab. 


Preferred Secure Transport Methods

Below are the currently preferred transport methods for each Public Health objective. Additional mechanisms might be available for each objective and can be discussed upon establishment. 

Preferred Transport Methods For Public Health Objectives

Interface

Secure File Transport Protocol (SFTP)

Web Services (using the TDH WSDL)

Direct Messaging

Immunization Registry

Yes

Yes

No

Electronic Laboratory Reporting

Yes

No

No

Cancer Case Reporting

Yes

No

Yes

Syndromic Surveillance (EHs w/Emergency Department)

Yes

No

No