PROMOTING INTEROPERABILITY (PI)

The Center for Medicaid and Medicare’s (CMS) EHR Incentive Program, commonly known as Promoting Interoperability (previously known as Meaningful Use) and the Medicare Access and CHIP Reauthorization Act (MACRA) Quality Payment Program have expanded the use of Electronic Health Record (EHR) Systems and increased the ability for Eligible Hospitals, Critical Access Hospitals, Eligible Providers and Eligible Clinicians to efficiently report their public health data electronically through interoperable health information technology (HIT). See the right-hand menu for links to key Promoting Interoperability (PI) information.

Important note about the continuation of the Promoting Interoperability (PI) program

Providers who have registered for the Medicaid EHR incentive program through 2016 can still attest to and receive Medicaid EHR incentive payments through 2021.

The Medicare EHR incentive program has been combined with the Medicare provider quality reporting programs under the MACRA legislation. Eligible Clinicians are now reporting the Promoting Interoperability measures under the Medicare Quality Payment Program. Although there are some exemptions for this program, the Promoting Interoperability program is not over.

Check your individual or group eligibility on the QPP home page.

Limitations of Public Health Agencies Role in EHR

Promoting Interoperability does NOT create a mandate for Public Health Agencies to:

  • Set or clarify PI The standards have been created by the Office of the National Coordinator (ONC), and only ONC can interpret its intention in the standards
  • Certify providers as meeting any PI standard. ONC/CMS determine eligibility for incentive payments, and other providers are required to self-certify as having met ONC’s standards. Public Health’s role is maintaining public health registries and providing the Local Implementation Guide to delineate data exchange standards.
  • Adapt its public health registries to accommodate non-standard (i.e. other than HL7 2.5.1) Electronic Health Record (EHR) submissions. PI specifically requires that the EHR product be certified. However, certification alone does not guarantee successful interoperation. Public Health still has the responsibility to set the standards for data exchange to its registries to maintain the quality of the public health data.
  • Support the installation or configuration of any EHR. This is the vendor’s role. 1

1https://www.cdc.gov/vaccines/programs/iis/meaningful-use/index.html

Declaration of Readiness

The Montana Department of Public Health and Human Services (DPHHS) has the capability to receive electronic messages to help facilities meet Promoting Interoperability requirements.

DPHHS is participating in the following Public Health objectives for Stage 2, Modified Stage 2, and Stage 3 Promoting Interoperability Core Measures.

Core measures:

Syndromic Surveillance

  • Submission of Emergency Department (ED) visits
  • EHs and Critical Access Hospitals (CAHs) with Emergency Departments may register
  • EPs may register only if emergency care (like an EH Emergency Department) is provided
  • Submission of other visit types (urgent care, inpatient, outpatient, etc)
  • Montana DPHHS is not ready to accept data from these types of visits
  • There are no plans to accept these visits during the 2018 calendar year
  • If you are unsure about whether your EP or CAH qualifies for an exclusion, you are encouraged to complete the Promoting Interoperability Registration (link below) to receive an individualized review of your clinic.

Cancer Case Reporting

  • Identify and report cancer cases electronically to the Montana Central Tumor Registry for eligible professionals.

Immunizations

  • Submit electronic data to the immunization registry for eligible professionals (EP) and hospitals (EH) compliant with HL7 2.5.1 CDC Standards 2
  • Ability to respond to bidirectional queries (QBP/RSP) starting on January 1, 2017 3
  • The capacity to receive NDC codes starting on January 1, 20173 (Note: CVX code will still be required)
  • Transport method(s) supported:
    • HTTPS POST
    • SOAP
  • CEHRT Editions accepted 4: 2014 & 2015 CEHRT

2https://www.cdc.gov/vaccines/programs/iis/technical-guidance/downloads/hl7guide-1-5-2014-11.pdf

3https://www.cdc.gov/ehrmeaningfuluse/docs/Guidance-for-Public-Health-Agencies-Meaningful-Use-in-2017.pdf

4https://www.cms.gov/regulations-and-guidance/legislation/ehrincentiveprograms/certification.html

Electronic Laboratory Reporting (ELR)

  • Provide electronic submission of reportable laboratory results (ELR) for eligible hospitals (EH) only.
  • To establish an ELR connection with MTDPHHS, please register for onboarding by completing the “DPHHS Public Health Promoting Interoperability Registration” survey located at the bottom of this page.

Electronic Case Reporting (eCR)

  • The Montana Department of Public Health and Human Services (MTDPHHS) supports submission of Electronic Case Reporting (eCR) for Promoting Interoperability (PI) from Eligible Hospitals (EH) and Critical Access Hospitals (CAH).
    • NOTE: Promoting Interoperability does not apply for non-hospital providers. However, MTDPHHS can work with any provider or non-hospital facility that wants to implement eCR to help automate/facilitate the reporting of reportable conditions via eCR.
  • Submission Methods: As of November 2021, MTDPHHS is only accepting eCRs through APHL Informatics Messaging Service (AIMS) Platform.
  • The process of onboarding a facility to production eCR can take several months to complete. It is expected that the facility will continue to maintain a manual reporting feed throughout the onboarding process and beyond, until the MTDPHHS can do a QA check to validate the eCR matches the manual reporting feed.
  • The reporting facility will be notified by MTDPHHS when they can turn off their manual reporting feed.

Registration of Intent

To register your intent with DPHHS, please click on the link below:

DPHHS Public Health Promoting Interoperability Registration

 

For more information, please e-mail PublicHealth@mt.gov.