eHealth Consulting News and Updates: PHO

Greetings! Can you believe it is already the second week in February? I can’t. What significance does that hold? It means that you have 21 more days to become “Actively Engaged” with a public health registry. It also means that PQRS submissions will be due soon as well. Different registry vendors have different cut off dates, so make sure you are familiar with yours.

There is a lot of buzz lately about public health options, so I wanted to take a few minutes to review some key points. First and foremost, the intent of the measure is to exchange meaningful data with another entity that can use the data to generate meaningful results. It isn’t intended to be an exercise in futility. In addition, a “public health registry is one that is administered by, or on behalf of a local, state, territorial, or national PHA and which collects data for public health purposes.”

There are three measures:
Measure 1 - Immunization Registry Reporting: active engagement with a PHA to submit immunization data.
Measure 2 – Syndromic Surveillance Reporting: active engagement with a PHA to submit syndromic surveillance data.
Measure 3 – Specialized Registry Reporting: active engagement to submit data to a specialized registry.
EP Spec Sheet at CMS.gov 

So how can you meet these measures?
The first two are pretty straightforward, the public health agency in your state either has an Immunization Registry or Syndromic Surveillance registry or it does not and you can typically find a statement to that effect on your state Department of Public Health website. Documentation of your registration to participate, participation, or documentation that the PHA does not currently have an Immunization or Syndromic Surveillance registry available are important for audit purposes. 

If you registered last year or in a previous year and there has been no change in the availability, you do not have to register again. As noted in the specification sheet, registration allows the EP to meet the measure despite the PHA’s limited resources to move forward. Registration must occur within the first 60 days of the reporting period (no later than 2/29/2016). If there is no registry at the beginning of the reporting period, you qualify for an exclusion. Other exclusions can be found on the EP Spec Sheet link above.

If you are excluded from either Immunization Registry or Syndromic Surveillance or both, you must look to the Specialized Registry options. You can use two specialized registries to meet the Public Health Options measure. You can also use “methods beyond the functions of the CEHRT to meet the requirements”. This means you can think outside the box and you do not necessarily have to purchase something extra to meet the measure. The word “jurisdiction” is also a key part of the Specialized Registry measure.

“An EP must complete two actions in order to determine available registries or claim an exclusion:
•    Determine if the jurisdiction (state, territory, etc.) endorses or sponsors a registry; and,
•    Determine if a National Specialty Society or other specialty society with which the provider is affiliated endorses or sponsors a registry.”

Recommendations:
1.    Contact your public health agency (ideally by email so you have documentation) to ask about specialized registries that are pertinent to your specialty.
2.    Contact your specialty local, state, and/or national organization (ideally by email so you have documentation) to ask if there are opportunities for data sharing. 
3.    Contact the HIE in your state, if available, and find out the data sharing capabilities and if appropriate, register your intent to participate.
4.    Attend the Reporting Module class to discover what you can already do with your data.