Guidance on Stage 1 Meaningful Use Objectives
We get questions everyday from our readers about meaningful use and these three are asked regularly. CMS has recently documented guidance on them in their FAQ database.
For meaningful use stage 1 objectives that require a provider to test the transfer of data, such as “capability to exchange key clinical information” and testing submission of data to public health agencies, can the EP, eligible hospital or CAH conduct the test from a test environment or test domain of its certified EHR technology in order to satisfy the measures of these objectives?
Yes, it is acceptable to conduct a test of information exchange from a test environment or test domain of certified EHR technology in order to satisfy the measures of the objective for “capability to exchange key clinical information” or any of the public health objectives (e.g., immunization registry, syndromic surveillance, or reportable lab results). A provider can also use simulated data when conducting these tests-the use of test information about a fictional patient that would be identical in form to what would be sent about an actual patient would satisfy these objectives.
However, it is important to note that in order to meet this stage 1 meaningful use objective for “capability to exchange key clinical information,” the provider must conduct the test with another provider of care with distinct certified EHR technology or other system capable of receiving the information. Simulated transfers of information or transfers of information through means that do not reach another provider of care (e.g., “dummy” websites that exist solely for providers to send information) are not acceptable to satisfy this objective.
Similarly, to meet any of the public health objectives, the provider’s test must involve the actual submission of information to public health agencies, and follow up submission is required if the test is successful. Please note that some public health agencies will not allow providers to submit test information about fictional patients. Providers submitting information to public health agencies that do not allow test information must submit actual patient information as a test in order to satisfy the measures of these objectives.
For meaningful use stage 1 objectives that require a provider to test the transfer of data, such as “capability to exchange key clinical information” and testing submission of data to public health agencies, if multiple EPs are using the same certified EHR technology across several physical locations, can a single test serve to meet the measures of these objectives?
No, if multiple EPs are using the same certified EHR technology in different physical locations/settings (e.g., different practice locations), there must be a single test performed for each physical location/setting. This is true even if the certified EHR technology that is used in the different physical locations is connected to the same server. The purpose of this testing is to demonstrate that the information can be transferred from where it was created (the physical location/setting of the EP or group of EPs) to another provider of care, patient-authorized entity or public health agency. While we understand that several different physical locations/settings may send this information through a central server or on mostly the same path, there may be some degree of variation in the path of transmission or the infrastructure involved.