Steps for Meaningful Use Testing and Submission to Michigan Public Health Systems
In Stage 2, providers in general will be required to enter Ongoing Submission of data to public health agencies, and transmit data appropriately over the course of the full EHR reporting period. Public Health agencies in Michigan frequently refer to this status as “Production Submission.” There are certain exceptions to entering full “production” that will still meet the Ongoing Submission requirements of Stage 2. (See Step 3 below.)
MDCH is required to declare the readiness of each of its public health systems and registries to receive electronic submissions of clinical data for Stage 2 of Meaningful Use. CMS intends to develop a centralized list (“CMS repository”) of this readiness information that covers all 50 states. If MDCH fails to declare its capability for a given system in the CMS repository prior to the EHR reporting period, the provider may claim an exclusion from the relevant measure. MCIR, MDSS, MSSS, and the Cancer Registry intend to declare their readiness when the CMS repository is available. Until then, EPs and EHs must consult the Statement on the Availability of Public Health Systems to Conduct Meaningful Use Testing, below, to determine their eligibility for exclusion. EPs and EHs are required to check the CMS repository within 60 days of the start of their Stage 2 EHR reporting period. If the registry with which they wish to initiate ongoing submission is not ready to receive data, the provider may claim an exclusion from the relevant measure. In the event that CMS does not have the aforementioned Public Health Readiness repository established by August 1, 2013, please refer to the “Statement on the Availability of Public Health Systems to Conduct Meaningful Use Testing” using the button below.
Statement on the Availability of Public Health Systems to Conduct Meaningful Use Testing
EPs and EHs must register their intent to move to Ongoing Submission with the appropriate public health registry within 60 days of the start of their Stage 2 EHR reporting period. Failure to do so will result in failing the relevant Stage 2 MU measure. Michigan requires that this intent be registered as part of Stage 1 Year 2 of Meaningful Use. Therefore, if you registered in stage 1 and met the stage 1 year 2 requirement, you do not need to register for stage 2 unless you have relocated to a different practice. You will receive an e-mail confirming your status. The Stage 2 Final Rule allows for 4 possible scenarios where a provider may be deemed to meet the Ongoing Submission requirements:
- Ongoing submission was already achieved for an EHR reporting period in a prior year and continues throughout the current EHR reporting period.
- Registration with the PHA or other body to whom the information is being submitted of intent to initiate ongoing submission was made by the deadline (within 60 days of the start of the EHR reporting period) and ongoing submission (production) was achieved.
- Registration of intent to initiate ongoing submission was made by the deadline and the EP or hospital is still engaged in testing and validation of ongoing electronic submission.
- Registration of intent to initiate ongoing submission was made by the deadline and the EP or hospital is awaiting invitation to begin testing and validation. (The EP/EH must still be awaiting this invitation at the end of the EHR reporting period in this scenario. Otherwise, scenario 3 would most likely apply.) Consult the “Statement on Availability” above to see for which systems this could apply.
Different Public Health Systems may have different specific requirements for qualifying under each of the 4 scenarios above. Please follow any instructions public health personnel give you, and refer to the system-specific pages on the MichiganHealthIT.org Public Health section.
- IMPORTANT! If a public health agency sends a written request for movement toward ongoing submission, an EP or EH must respond within 30 days. Failure to do so, on two separate occasions, may result in failing the relevant Stage 2 Meaningful Use measure. If you receive notification of a failure that you wish to appeal, contact DCHPublicHealthMU@michigan.gov. DO NOT contact the public health agency to dispute a failure.