Archived Public Health FAQs
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Contents
- What should I do if the EHR Reporting Period entered in the Meaningful Use Registration for Public Health (MURPH) System ends up being different than the EHR Reporting Period the provider will attest to?
- I received notification of my status with a Public Health Registry for one or more Meaningful Use Stage 2 Public Health Objectives. How can I determine what my status is for 2015 under the new Modified Stage 2 Public Health Reporting Objective?
- Our Eligible Professional (EP) or Eligible Hospital (EH) attested to a third or fourth year of Meaningful Use Stage 1 (MU1) for Payment Year 2014 under the new Centers for Medicare and Medicaid Services (CMS) Flexibility Rule. Does attesting to an extra year of MU1 negate the requirement of attesting to two years of Meaningful Use Stage 2 (MU2) or push back the two years of MU2 to 2015 and 2016 and extend the overall Meaningful Use timeline?
- The Centers for Medicare and Medicaid Services (CMS) has released a Frequently Asked Question (FAQ) stating that "Providers only need to register once, with the Public Health Agency (PHA) or other body to whom the provider will be submitting data, to indicate their intent to initiate ongoing submission of data to meet public health objectives [in the Medicare and Medicaid EHR Incentive Programs]." According to the NY Medicaid Public Health Objective Support Team´s guidance, a new registration is required for each year of participation in the EHR Incentive Program. Why is this?
- Who do I contact if I would like to test with Public Health Registries to meet Meaningful Use Stage 1 requirements?
- Does the test message an Eligible Provider submitted to a Public Health Registry in a previous year count towards meeting the Meaningful Use (MU) Stage 1 Public Health Objective for the current EHR Reporting Period?
- How can an Eligible Professional in Meaningful Use Stage 2 Year 1 register intent for payment year 2015 in the Meaningful Use Registration for Public Health (MURPH) System? When the Meaningful Use Start Date of January 1, 2015 is entered, the system automatically generates a Meaningful Use End Date of March 31, 2015 instead of the full year EHR reporting period as required by Meaningful Use Stage 2 in Payment Year 2015 and beyond?
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2.3 What should I do if the EHR Reporting Period entered in the Meaningful Use Registration for Public Health (MURPH) System ends up being different than the EHR Reporting Period the provider will attest to?
Published: 01/05/2015
Updated: 09/28/2016
Date Archived: 12/27/2016
The EHR Reporting Period specified in the Eligible Provider´s EHR Incentive Program Attestation is the authoritative timeframe for compliance and the EHR Reporting Period specified in the Public Health Registration is used as guidance to inform the onboarding process. Whenever possible, we do highly recommend that these periods coincide, but a provider would only be audited on the EHR Reporting Period specified in Eligible Provider´s EHR Incentive Program Attestation. An important caveat with changing the EHR Reporting period to keep in mind is that the registration in the Meaningful Use Registration for Public Health (MURPH) System must be submitted before or within 60 days of the start of the EHR Reporting Period to meet Active Engagement Option 1: Completed Registration to Submit Data.
PH37 I received notification of my status with a Public Health Registry for one or more Meaningful Use Stage 2 Public Health Objectives. How can I determine what my status is for 2015 under the new Modified Stage 2 Public Health Reporting Objective?
Published: 12/11/2015
Updated: N/A
Date Archived: 12/27/2016
Despite the changes to Public Health Reporting defined in the Stage 3 and Modifications to Meaningful Use in 2015 Through 2017 Final Rule, the attestation guidelines for the Meaningful Use Stage 2 Public Health Objectives and the new Modified Stage 2 Public Health Reporting Objective are very similar. Eligible Providers may continue to use the compliance documentation they have received in 2015 to support their attestation.
In order to attest "yes" to a Modified Stage 2 Public Health Reporting Measure, an Eligible Provider must be in active engagement with a Public Health Registry. CMS states in the Public Health Reporting 2015 Specification Sheet that "any providers who have already planned for and engaged in activity to meet any of the Stage 1 or Stage 2 public health reporting objectives may count those actions toward meeting the similar or equivalent active engagement option."
Please review the table below to determine which option of active engagement applies to you based on your current status with the Public Health Registry.
| Current Status | Active Engagement |
|---|---|
| Awaiting Invitation to Test | Option 1 – Completed Registration to Submit Data |
| Engaged in Testing | Option 2 – Testing and Validation |
| Ongoing Submission | Option 3 – Production |
Additional Resource:
- Public Health Reporting Objective 2015 Specification Sheet for EPs
- Public Health Reporting Objective 2015 Specification Sheet for EHs
- Public Health FAQ #4.4
PH17 Our Eligible Professional (EP) or Eligible Hospital (EH) attested to a third or fourth year of Meaningful Use Stage 1 (MU1) for Payment Year 2014 under the new Centers for Medicare and Medicaid Services (CMS) Flexibility Rule. Does attesting to an extra year of MU1 negate the requirement of attesting to two years of Meaningful Use Stage 2 (MU2) or push back the two years of MU2 to 2015 and 2016 and extend the overall Meaningful Use timeline?
Published: 01/05/2015
Updated: N/A
Date Archived: 12/27/2016
The MU2 timeline is "extended" for an EP or EH attesting to MU1 for a third or fourth year in Payment Year 2014. This means an EP or EH will still be required to complete two years for MU2 reporting in 2015 and 2016. Table 3 from the CMS Flexibility Rule illustrates the new timeline for providers exercising this new flexibility. Note the overall timeline for providers choosing Stage "1 or 2" in payment year 2014 in the table below. For more information about the extension of MU2, please review section 79 FR 52926 of the CMS Flexibility Rule.
Table 3—Proposed Stage of Meaningful Use Criteria by First Payment Year
| Stage of meaningful use | |||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|
| First payment year |
2011 | 2012 | 2013 | 2014 | 2015 | 2016 | 2017 | 2018 | 2019 | 2020 | 2021 |
| * 3–month quarter EHR reporting period for Medicare and continuous 90–day EHR reporting period (or 3 months at State option) for Medicaid EPs. All providers in their first year in 2014 use any continuous 90–day EHR reporting period. | |||||||||||
| 2011 | 1 | 1 | 1 | 1 or 2* | 2 | 2 | 3 | 3 | TBD | TBD | TBD |
| 2012 | 1 | 1 | 1or 2* | 2 | 2 | 3 | 3 | TBD | TBD | TBD | |
| 2013 | 1 | 1* | 2 | 2 | 3 | 3 | TBD | TBD | TBD | ||
| 2014 | 1* | 1 | 2 | 2 | 3 | 3 | TBD | TBD | |||
| 2015 | 1 | 1 | 2 | 2 | 3 | 3 | TBD | ||||
| 2016 | 1 | 1 | 2 | 2 | 3 | 3 | |||||
| 2017 | 1 | 1 | 2 | 2 | 3 | ||||||
CMS Flexibility Rule, Table 3, 79 FR 52927
PH30 The Centers for Medicare and Medicaid Services (CMS) has released a Frequently Asked Question (FAQ) stating that "Providers only need to register once, with the Public Health Agency (PHA) or other body to whom the provider will be submitting data, to indicate their intent to initiate ongoing submission of data to meet public health objectives [in the Medicare and Medicaid EHR Incentive Programs]." According to the NY Medicaid Public Health Objective Support Team´s guidance, a new registration is required for each year of participation in the EHR Incentive Program. Why is this?
Published: 04/09/2015
Updated: 11/10/2015
Date Archived: 12/21/2016
Since the CMS FAQ was released, the NY Medicaid EHR Incentive Program has updated its policy to align with CMS guidance. An Eligible Provider who has registered intent during a previous payment year does not need to submit a new registration for each subsequent payment year. However, the CMS FAQ goes on to state that "PHAs may periodically ask providers to verify or update the information from the initial registration. PHAs use the information collected to manage communication and prioritization of their onboarding processes." The NY Medicaid EHR Incentive Program will require Eligible Providers participating in either the Medicaid or Medicare EHR Incentive Programs and attesting "Yes" to the Meaningful Use Public Health Reporting Objective to update their registration of intent every payment year.
Please be aware that as an Eligible Provider, you are responsible for:
- Meeting Public Health Reporting Objective onboarding deadlines such as registering intent to submit data within 60 days of the start of one´s EHR Reporting Period.
- Securing documentation such as registration, testing and submission of production data confirmations from each registry to support any potential pre-payment and/or post-payment audits.
- Saving audit documentation for up to six years after an EHR Incentive Payment is approved.
Additional Resource: CMS FAQ#11964
PH14 Who do I contact if I would like to test with Public Health Registries to meet Meaningful Use Stage 1 requirements?
Date Archived: 11/10/2015
To help formalize the Meaningful Use Stage 1 testing process, Eligible Providers are encouraged to declare their intent to test for a given Public Health Objective using the MU1 Public Health Testing Request Form. Once this form has been submitted, the information collected will be sent to the appropriate Public Health Registry. Testing instructions will be sent to the Eligible Provider via the Primary Contact´s and Technical Contact´s email addresses. Please review the Public Health Objective Guidance and reporting Website for step-by-step registry instructions on how to complete Meaningful Use Stage 1 testing process.
PH33 Does the test message an Eligible Provider submitted to a Public Health Registry in a previous year count towards meeting the Meaningful Use (MU) Stage 1 Public Health Objective for the current EHR Reporting Period?
Date Archived: 11/10/2015
No, a test message submitted to a Public Health Registry in a previous year does not count towards meeting the MU Stage 1 Public Health Objective for any subsequent year. Engagement with the Public Health Registry is required during each payment year in order for an Eligible Provider to attest "yes" to a Public Health Objective. It is not acceptable to use a test from Stage 1 Year 1 to meet the Public Health Objective in Stage 1 Year 2.
Additional Resource: CMS FAQ#8910
PH19 How can an Eligible Professional in Meaningful Use Stage 2 Year 1 register intent for payment year 2015 in the Meaningful Use Registration for Public Health (MURPH) System? When the Meaningful Use Start Date of January 1, 2015 is entered, the system automatically generates a Meaningful Use End Date of March 31, 2015 instead of the full year EHR reporting period as required by Meaningful Use Stage 2 in Payment Year 2015 and beyond?
Date Archived: 11/10/2015
The EHR Incentive Program is aware of this issue in the Meaningful Use Registration for Public Health (MURPH) System. Eligible Professionals should continue submitting registrations with the appropriate Meaningful Use Start Date. If a date of January 1, 2015 is entered, the EHR Incentive Program will know that the Meaningful Use End Date should be December 31, 2015. Please remember that Eligible Professionals must register their intent to initiate ongoing submission for each Public Health Objective within 60 days of the start of the EHR Reporting Period.
The information collected during registration is used to inform the EHR Incentive Program and Public Health registries in order to guide onboarding activities. We ask that you make every effort to ensure the information entered is as accurate as possible, however please note that registration information will not impact attestation or a potential audit. The EHR Reporting Period entered in the Eligible Professional´s attestation will be the only timeframe used to determine compliance with the EHR Incentive Program.
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