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Electronic Case Reporting Requirements Explained


MIPS EHR Quality 2022 Promoting Interoperability

Electronic case reporting (eCR) is now required under the MIPS Promoting Interoperability (PI) category and in hospital and facility Promoting Interoperability Programs (PIP). Many clinicians are not familiar with what the eCR measure entails as, in previous years, they used other measures to fulfill the PI Public Health and Clinical Data Exchange objective's requirements.

This article explains why this measure is now required, what the measure entails, and how to determine your best course of action.

Why is eCR Now Required?

The COVID-19 pandemic highlighted the inability of US public health infrastructure to respond to large scale crises. The exchange of COVID-19 data between health care providers and public health agencies (PHAs) was slow and, often, either incomplete or not actionable. 

Health care providers often had to exchange or report this information manually, a slow process that introduced error and lended itself to yielding incomplete data. Moreover, the manual process is burdensome, especially for already overextended health care providers trying to deal with a public health crisis unlike any in our lifetimes. 

eCR allows automated, real-time exchange of relevant clinical data between EHRs and PHAs and streamlines the case reporting process. However, up until the COVID-19 pandemic, PHAs often had not enabled eCR functionality, and EHRs, thus, had little incentive to develop the functionality.

To provide this incentive and to facilitate less burdensome, more complete, and more accurate public health reporting in the future, CMS decided to require electronic case reporting beginning in performance year 2022.

For Whom is eCR Required?

Anyone reporting MIPS PI or in the Promoting Interoperability Programs. 

What eCRs Are Acceptable?

You must register with your PHA if they have indicated readiness to accept electronic case reporting submissions. Check your state's eCR site for more information. To make this easier, use this listing from the Office of the National Coordinator (ONC) to get started. 

Many jurisdictions are now offering connections to their electronic case reporting systems through eCR Now's federal eCR. eCR Now is a joint project of the CDC, the Association of Public Health Laboratories, and the Council of State and Territorial Epidemiologists. The system allows providers to rapidly adopt and implement electronic case reporting either using existing capabilities within their EHR or by using the eCR Now FHIR app to add eCR functionality to their EHR.

Though access to the platform is free, depending on what you already have in place as part of your EHR, there may be additional costs to create a Direct connection with your EHR.

For more information, review this fact sheet and the CDC's eCR information page

The CDC also offers streamlined instructions on how providers can sign up.


What Are the Options to Fulfill the eCR Measure?

You must be in active engagement with a PHA to electronically submit case reports. CMS offers the following 3 options for active engagement:

  1. Option 1 – Completed Registration to Submit Data: The MIPS eligible clinician registered to submit data with the PHA or, where applicable, the Clinical Data Registry (CDR) to which the information is being submitted; registration was completed within 60 days after the start of the performance period; and the MIPS eligible clinician is awaiting an invitation from the PHA or CDR to begin testing and validation. This option allows MIPS eligible clinicians to meet the measure when the PHA or the CDR has limited resources to initiate the testing and validation process. MIPS eligible clinicians that have registered in previous years do not need to submit an additional registration to meet this requirement for each performance period.

  2. Option 2 – Testing and Validation: The MIPS eligible clinician is in the process of testing and validation of the electronic submission of data. MIPS eligible clinicians must respond to requests from the PHA or, where applicable, the CDR within 30 days; failure to respond twice within a performance period would result in that MIPS eligible clinician not meeting the measure.

  3. Option 3 – Production: The MIPS eligible clinician has completed testing and validation of the electronic submission and is electronically submitting production data to the PHA or CDR.

If you have multiple EHRs: As both MIPS PI and the other CMS Promoting Interoperability Programs measures the actions of clinicians and facilities based on all encounters and captured patient information in certified EHRs, you must be in active engagement to send electronic case reports with all EHRs at your practice or facility.

What Exclusions Are Available?

This measure has 4 exclusions:

  1. Clinician does not treat or diagnose any reportable diseases for which data is collected by their jurisdiction's reportable disease system during the performance period. OR
  2. Operates in a jurisdiction for which no PHA is capable of receiving electronic case reporting data in the specific standards required to meet the CEHRT definition at the start of the performance period. OR
  3. Operates in a jurisdiction where no PHA has declared readiness to receive electronic case reporting data as of 6 months prior to the start of the performance period.
  4. (For 2022 only) The MIPS eligible clinician uses CEHRT that is not certified to the electronic case reporting certification criterion at § 170.315(f)(5) prior to the start of the performance period they select in CY 2022.

To claim exclusion 4, first check to see if your EHR is certified to the electronic case reporting criterion using these steps:

  1. Visit the ONC Certified Health IT Product List (CHPL)  
  2. Enter your EHR vendor and select the correct product OR enter your EHR's CHPL ID
  3. Click on the listing
  4. Select the correct product and product number
  5. Expand "Certification Criteria"
  6. Look for either of the below:
    • "170.315(f)(5): Transmission to public health agencies — electronic case reporting" OR
    • "170.315(f)(5): Transmission to public health agencies — electronic case reporting (Cures)"
  7. If you see either of the above, your EHR is certified to the criterion and, if it was certified to these criterion before 01/01/2022, you cannot claim exclusion 4. If you see neither, you can claim exclusion 4.

How is the eCR Measure Scored?

This is an attestation measure, meaning that you check Yes, No, or claim an exclusion. The eCR measure, along with the Immunization Registry measure, is 1 of the 2 required Public Health and Clinical Data Exchange measures. These required measures are scored together with the following scenarios as options:

  1. Attest "Yes" to both required measures and get 10 points toward your MIPS PI score.
  2. Attest "Yes" to 1 and claim an exclusion to the other required measure and get 10 points toward your MIPS PI score.
  3. Claim an exclusion to both required measures and the 10 points will be redistributed to the Provide Patients Electronic Access to Their Health Information measure.
  4. Attest "No" on either required measure and receive 0 points for the entire PI category.

 

Next Steps

  • Share this information with your colleagues.
  • Subscribe to our newsletter to get alerts on this and other important issues. You can subscribe using the field in our website footer below.
  • If you are a MarsdenAdvisors client
    • If you have not already done so, schedule your 2022 kickoff call and watch the pre-kickoff presentation.
    • Contact your Client Success Manager if you have any questions.
  • If you are not a MarsdenAdvisors client
    • Contact us to learn more about our MIPS Success Plan and to reap the rewards of our combined decades of experience.
    • Consider reaching out to the CDC's eCR to learn more about how to start the sign up process.

If you have any questions on this, let us know! 

Jessica Peterson

Written by Jessica Peterson

Jessica Peterson, MD, MPH is the Vice President of Health Policy at the consulting firm MarsdenAdvisors.

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