Are You Ready for the Updated CMS eCR Mandate?

Public Health Reporting requirements on conditions specified by The Centers for Disease Control (CDC), The Centers for Medicaid and Medicare (CMS), and other related healthcare organizations have been part of Promoting Interoperability (PI)—formerly known as Meaningful Use1—since its inception. While public health reporting requirements have changed throughout program iterations, it was likely that some requirements would become obsolete around 2019.  

However, along with other considerations, the onset of the COVID-19 pandemic amplified the value in electronic reporting, resulting in a volte-face in CMS’ stand around the need for its continued use and certification. As part of the 2022 Inpatient Prospective Payment System (IPPS) rule, CMS mandated that health care facilities participating in PI must report for at least 90 days in Calendar Year 2022 (CY2022) on the following to qualify for federal healthcare incentives and avoid penalties. 

• 170.315 (f)(1) – Transmission to immunization registries 
• 170.315 (f)(2) – Transmission to public health agencies – Syndromic Surveillance 
• 170.315 (f)(3) – Transmission to public health agencies – Reportable lab tests and values/results 
• 170.315 (f)(5) – Transmission to public health agencies – electronic case reporting 

Why Mandate Electronic Case Reporting for Public Health? 

In mandating electronic case reporting on these specified conditions, CMS hopes to improve monitoring for public health emergencies while simultaneously providing a pathway for speedier and more efficient responses to such outbreaks.  

While there are no specific content exchange standards per the regulation, the mandate will require:  

• Support for maintaining reportable conditions that should trigger a case report to public health agencies 
• A minimum data set that should be included in the case report  
• An identifier for the reportable condition 
• The version of the reportable conditions database that was used to trigger the report 

What eCR 2022 Means for Healthcare Providers 

One of the main challenges this mandate presents to the facilities is short on-boarding time. The quick turnaround needed to meet a CY2022 deadline is further complicated when considering state-specific variations in their ability to accept case reports. 

How MEDHOST Helps Hospitals Prepare 

MEDHOST has supported the capability to report on the first three requirements (immunization registries, syndromic surveillance, and reportable lab tests and values/results) since the onset of the Meaningful Use Program. To ensure customers meet the program’s requirements, MEDHOST is also introducing support for 170.315 (f)(5) – Transmission to public health agencies – electronic case reporting.  

In its current state, the MEDHOST Electronic Case Reporting solution features: 

• Reportable trigger condition checks and automatic updates of the codes, thus allowing the facility to be compliant with a minimal overhead of maintaining the reportable conditions 
• Generation of case report for encounters matching trigger conditions with no disruption to user workflows 
• Transmission of the case report to the public health agency 

In keeping with MEDHOST’s endeavors to offer the best solutions to our customers, the MEDHOST 2022 R1 release will support the eCR Now application that will rely on FHIR integration. eCR is now a recommended solution from the ONC as a standardized mechanism of case reporting and will keep our customers on par with the industry. This integration will be available for adoption in CY2022 and is a MEDHOST best practice recommendation. 

To address any concern over the 90-day reporting requirement in CY2022, MEDHOST is offering this functionality in MEDHOST Enterprise 2021 R1 by modifying the Continuity of Care Document (CCD) to include information on reportable conditions. The functionality will also exist to maintain the list of reportable conditions automatically. 

To learn more about ECR and this critical Promoting Interoperability capability, please reach out to your Customer Success Executive or inquiries@medhost.com.  

1 MEDHOST Enterprise 2019 R1, The Business Intelligence v5.5, MEDHOST EDIS 2019 R1 MEDHOST Enterprise, The Business Intelligence, MEDHOST EDIS 1 and MEDHOST Cloud Services Patient Portal with YourCareEverywhere ® App products and MEDHOST Cloud Services API are ONC 2015 Edition-compliant and have been certified by an ONC-ACB in accordance with the applicable certification criteria adopted by the Secretary of the US Department of Health and Human Services. This certification does not represent an endorsement by the US Department of Health and Human Services or guarantee the receipt of incentive payments. For a complete review of the EHR certification and accompanying "Cost and Limitations" statements, visit https://www.medhost.com/about-us/regulatory-and-compliance/"https://www.medhost.com/about-us/regulatory-and-compliance/.