A new tip sheet from CMS provides clarifications on the modified Stage 2 Health Information Exchange (HIE) objective (formerly known as “Summary of Care”), which is required for providers planning to achieve meaningful use in 2015 through 2017.
As with the prior Stage 2 rules, the modified Stage 2 objective requires that the provider “who transitions their patient to another setting of care or provider of care, or refers their patient to another provider of care, provides a summary care record for each transition of care or referral.”
Also unchanged is the requirement to report two separate measures in 2016 and 2017:
(1) Use certified EHR technology (CEHRT) to create a summary of care record; and
(2) Electronically transmit such summary to a receiving provider for more than 10 percent of transitions of care and referrals.
What’s New in the Rules
These measures, the limited exclusions that apply to them, and the requirement to use the C-CDA-based Summary of Care document have not changed from the prior Stage 2 requirements. However, the CMS explanation for what constitutes “electronic transmission” has.
According to the new tip sheet, “The summary of care record must still be created using C-CDA that is certified by the CEHRT, however, it does not need to be sent using a certified transfer mechanism. The provider may use a third party to send the summary of care record, but it is not required.”
The tip sheet goes on to say if a provider does use a third party, “the service the third party provides does not have to be certified for the transmission to be counted in the numerator for measure 2.” Furthermore, CMS states: “There are also no specific requirements around the technical standards or methods by which the third party delivers the summary of care document to the receiving provider (e.g., SOAP, secure email, fax).
The tip sheet suggests that providers can use a number of mechanisms, including “secure email, Health Information Service Provider (HISP), query-based exchange or use of third-party HIE”, and suggested there are other options beyond these “as long as the transmission methods are in compliance with HIPAA requirements.”
What Does This Mean for NextGen Healthcare Clients?
Previous Stage 2 rules referenced the 2014 Edition certification criteria and required providers to use specific standards for electronically transmitting the C-CDA. NextGen Healthcare certified for this criteria—specifically the capability to transmit the C-CDA electronically using the Direct standard. We released this capability to clients, first through the Direct interface and later through NextGen® Share, a free service from NextGen Healthcare.
The CMS tip sheet clarifies there is no longer a requirement to use Direct. In certain instances, this may be beneficial to clients (for example, if providers in the client’s referral network are unable to receive the C-CDA using Direct). However, clients utilizing one of these alternate methods will need to manually track the numerator for this measure outside of NextGen® Ambulatory EHR and NextGen® Health Quality Measures (NextGen HQM).
In addition to providing a free and simplified approach to managing C-CDA exchanges and referrals, NextGen Share is now available for reporting to a number of specialized registries, as required under the Public Health Reporting objective. We therefore encourage clients who have not done so to implement NextGen Share and take advantage of these capabilities.