Technical outcome – A user can create a report that includes the numerator, denominator, and resulting percentage for each applicable percentage-based Promoting Interoperability Programs measure supported.
Clarifications:
- There is no standard required for this certification criterion.
- ONC administers the ONC Health IT Certification Program; CMS administers the Promoting Interoperability and Quality Payment Programs. Questions regarding requirements for the Promoting Interoperability and Quality Payment Programs should be directed to CMS.
- Please refer to CMS’ Promoting Interoperability Programs webpage and Quality Payment Program webpage for more resources on specific measures.
- The test for (g)(2) does not require a live demonstration of recording data and generating reports. Developers may self-test their Health IT Modules(s) and submit the resulting reports to the ONC-ATL to verify compliance with the criterion. The test procedure specifies what reports must be submitted for each required test, as well as what the tester must verify within each report.
- Health IT Modules are required to de-duplicate test patients when aggregating together data for the Eligible Clinician Group calculation method.
- Health IT Modules that are testing for the MIPS Promoting Interoperability performance category calculation method must test for both the Eligible Clinician Individual and Eligible Clinician Group calculation methods.
- Health IT Modules that are testing for the Eligible Clinician Individual and Eligible Clinician Group calculation methods are required to be able to record an Eligible Clinician’s TIN. Further, they are also required to be able to associate a single NPI with multiple TINs within a single instance, database, etc. of the Health IT Module. Health IT Modules that are testing for the Individual Eligible Provider calculation method only are not required to record TIN or be able to associate a single NPI to multiple TINs.
- For the Eligible Clinician Individual and Eligible Clinician Group calculation methods, actions that accrue to the numerator have a transitive effect across all of the TINs that an individual NPI is included in. For example, if an Eligible Clinician provides patient education materials to a patient under TIN A, they will receive credit in the numerator for TIN B as long as the same NPI is used in both TINs and the same Health IT Module (i.e. same database, instance, etc.) is used. The test data reflects this transitive effect.
- The capability for technology to populate the numerator before, during, and after the reporting/performance period depends on the numerator and denominator statements for the Promoting Interoperability measure. Developers should refer to the numerator and denominator statements in the measure specification sheets provided by CMS’ Promoting Interoperability Programs webpage to determine the reporting/performance period technology needs to support. Regardless of whether an action must occur during the reporting/performance period or can occur outside of the reporting/performance period, all actions must occur during the calendar year of the reporting/performance period.
- Starting in 2019, CMS has clarified that the numerator for the Medicare Promoting Interoperability Program Eligible Hospital/Critical Access Hospital measures is constrained to the EHR reporting period. The numerator action therefore must take place during the reporting period. Actions occurring outside of the reporting period, including after the calendar year will not count in the numerator.
- Starting in 2019, a MIPS Promoting Interoperability performance category measure numerator and denominator is constrained to the performance period chosen, with the exception of the "Security Risk Analysis" measure, which may occur any time during the calendar year.
- It is possible for the action of “record” in this certification criterion to be implemented in different ways. For example, “record” could comprise the ability of a centralized analytics Health IT Module to accept or retrieve raw data from another Health IT Module(s). Other possible methods could include a Health IT Module that accepts or retrieves raw data, analyzes the data, and then generates a report based on the analysis; a Health IT Module that separately tracks each capability with a percentage-based Promoting Interoperability measure and later aggregates the numbers and generates a report; or an integrated bundle of Health IT Modules in which each of the Health IT Modules that is part of the bundle categorizes relevant data, identifies the numerator and denominator and calculates, when requested, the percentage associated with the applicable Promoting Interoperability Programs measure. In each of these examples, the action of “record” means to obtain the information necessary to generate the relevant numerator and denominator.
- What is required for certification for this criterion depends on the type of flexibility identified by CMS.
- In some cases, CMS identifies certain measurement flexibilities that are limited to “either/or” options. In these cases, technology presented for certification must be able to calculate the percentage based on both identified options.
- In cases where CMS has identified measurement flexibilities that are open-ended and dependent on a unique decision by an Eligible Professional, Eligible Clinician, Eligible Hospital, or CAH at the practice/organization-level for a given EHR reporting period (e.g., excluding certain orders from the CPOE measure because they are protocol/standing orders), then the technology presented for certification is not required to support every possible method of calculation in order to meet this certification criterion. Rather, the technology must support at least one calculation method for a certification criterion, as long as the technology supports all distinct options for measurement (e.g., including controlled substances in the eRx measure or not). ONC strongly encourages technology developers to work with their clients and to incorporate as many of these practice/organization-level open-ended flexibilities in the technology as appropriate to make the Promoting Interoperability measures as relevant as possible to their clients’ scopes of practice. [see also 77 FR 54244–54245]
- ONC also applies to this Automated measure calculation criterion the clarification and guidance included for certification to the Automated measure calculation criterion in the 2014 Edition Release 2 rulemaking [see also 79 FR 10920 and 54445].
- A Health IT Module may be certified to only the ‘‘Automated measure calculation’’ certification criterion (§ 170.315(g)(2)) in situations where the Health IT Module does not include a capability that supports a Promoting Interoperability Program percentage-based measure but can meet the requirements of the ‘‘Automated measure calculation’’ certification criterion.
- An example of this would be an ‘‘analytics’’ Health IT Module where data is fed from other health IT, and the Health IT Module can record the requisite numerators, denominators and create the necessary percentage report as specified in the ‘‘Automated measure calculation’’ certification criterion.
- The Support Electronic Referral Loops by Sending Health Information measure for the Medicare Promoting Interoperability Programs, and the MIPS Promoting Interoperability performance category require that the Eligible Professional/Eligible Clinician/Eligible Hospital/CAH confirm receipt of the summary of care by the referred to provider in order to increment the numerator. The test data tests this baseline requirement by requiring that a Health IT Module demonstrate confirmation of receipt before incrementing the numerator. ONC does not require a specific method Health IT Modules should use to confirm receipt. Health IT Modules could use a number of methods, including but not limited to, the Direct Message Disposition Notification, a check box, report verifications, etc.
- The test data used for this criterion is supplied by ONC and is organized into five test data scenarios, with a single set of 12 test cases. Health IT developers are required to use the ONC-supplied test data and may not modify the test case names.
- The Medicare Promoting Interoperability "Provide Patients Electronic Access to Their Health Information" measure requires that two conditions be met in order to increment/populate the numerator: patient data must be available to view, download, or transmit and it must be available to an API within 48 hours (Eligible Professional) or 36 hours (Eligible Hospital/CAH). The MIPS Promoting Interoperability performance category Provide Patients Electronic Access to Their Health Information measure requires that two conditions be met in order to increment/populate the numerator: patient data must be available to view, download, or transmit and it must be available to an API within four business days (Eligible Clinician). As such, Health IT Modules certified to only (e)(1) or certified to only (g)(9) or (g)(10) will be required to demonstrate that the product increments the denominator for the condition for which they are certified. For example, if the Test Case indicates that only view, download, or transmit was met, the numerator will increment for products certified to (e)(1) but will not increment for products certified to (g)(9) or (g)(10). Health IT Modules certified for (e)(1) and (g)(9) or (g)(10) will be expected to increment the numerator as the measure specifies. Health IT Modules certified to only (e)(1) or certified to only (g)(9) or (g)(10) will be required to provide documentation during testing that demonstrates how the Health IT Module performs the calculation for its “portion” of the measure as a condition of passing testing. This documentation must also be made available with the health IT developer’s transparency statement regarding costs and limitations. Documentation should enable Eligible Professionals, Eligible Clinicians, Eligible Hospitals, and Critical Access Hospitals to determine how to correctly add together the numerator and denominator from systems providing each of the capabilities.
- CMS has issued FAQ 22521 regarding the application of the transitive effect to certain MIPS Promoting Interoperability performance category measures. For the purposes of testing to this criterion, the test data is structured to differentiate actions between TIN/NPI combinations. However, Health IT Modules that are not able to differentiate actions between TIN/NPI combinations for the measures to which the transitive effect applies are not required to demonstrate this capability. ONC-ATLs may offer flexibility during testing regarding the transitive effect and focus on the outcome to ensure the correct numerator and denominator are calculated by the Health IT Module. At a minimum, developers of Health IT Modules unable to differentiate actions at the TIN/NPI level for those measures to which the transitive effect applies must provide sufficient documentation and explanation of alternate workflows to the ONC-ATL to demonstrate how actions taken by a provider relate to the numerator and denominator. Health IT developers must also provide documentation to providers on configuration and the logic for properly using the “Automated measure calculation” functionality, including details on how the developer has implemented the transitive effect policy.
- CMS has issued a series of FAQs that provide additional guidance on the new Medicare Promoting Interoperability Program measure for Eligible Hospitals in 2019: "Support Electronic Referral Loops by Receiving and Incorporating Health Information." The FAQs also apply in 2019 for the "Support Electronic Referral Loops by Receiving and Incorporating Health Information" measure in the MIPS Promoting Interoperability performance category.
- The Medicaid Promoting Interoperability Program ended January 2022, the required tests that only supported the Medicaid Promoting Interoperability Program were removed.