Promoting Interoperability

The U.S. Centers for Medicare and Medicaid Services has issued final rules for the Promoting Interoperability Program for fiscal year 2022. The U.S. CMS Promoting Interoperability Program – formerly the Electronic Health Record Incentive Program – provides financial incentives to providers if they use a certified EHR system to capture and use patient data meaningfully for care coordination, patient engagement and quality improvement purposes.

A connection to NC HealthConnex, the state-designated health information exchange, alone does not satisfy any single objective under the N.C. Medicaid EHR Incentive Program (part of the CMS Promoting Interoperability Program). However, full participation in NC HealthConnex can help health care organizations meet the updated measures related to the advancement of certified EHR technology utilization and improve interoperability.

Changes to the Medicare Promoting Interoperability Program

Final changes to the Medicare Promoting Interoperability Program for 2022 include:

• Maintaining an EHR reporting period of any continuous 90-days for new and returning participants (eligible hospitals and critical access hospitals) in the Medicare Promoting Interoperability Program for CY 2022
• Increasing the bonus points for the Electronic Prescribing Objective’s Query of Prescription Drug Monitoring Program measure from 5 points to 10 points
• Increasing the minimum scoring threshold from 50 points to 60 points
• Adopting the Health Information Exchange Bi-Directional Exchange measure as an alternative to the two existing measures (worth 40 points) under the Health Information Exchange Objective
• Requiring reporting on four of the Public Health and Clinical Data Exchange Objective measures: Syndromic Surveillance Reporting, Immunization Registry Reporting, Electronic Case Reporting and Electronic Reportable Laboratory Result Reporting, which is worth up to 10 points
• The Public Health Registry Reporting and Clinical Data Registry Reporting measures will remain optional for 5 bonus points.
• Requiring eligible hospitals and critical access hospitals to attest to having completed an annual assessment via the Safety Assurance Factors for EHR Resilience Guides measure, under the Protect Patient Health Information objective, beginning January 1, 2022.
• Revision of the required attestation statements due to similarities between practices described in the statements from the Medicare Promoting Interoperability Program’s prevention of information blocking requirements

CMS Final Rule Policies

• 2022 Final Rule
• Press Release
• Fact sheet

How NC HealthConnex Can Help

Full participation in NC HealthConnex and its features assists providers in meeting specific measures and objectives for the N.C. Medicaid EHR Incentive Program. While a connection alone does not satisfy any single objective, NC HealthConnex participation supports achieving objectives related to the following services and features.

Bidirectional Capabilities Confirmation

• NC HIEA can help determine whether your practice participates in a bidirectional exchange with a health information exchange to support care transitions, which CMS requires to be eligible for the Merit-Based Incentive Payment System.
• Fill out this request form so that the NC HIEA can confirm whether or not you participate in a bidirectional connection.

Health Information Exchange

• Electronic care transitions to outside EHRs via the NC HealthConnex Direct Secure Messaging XDR (EHR-integrated) service
• Searchable provider directory available through the NC HealthConnex portal and sent to full NC HealthConnex participants directly for use within their EHRs (updated quarterly)
• Query-based retrieval of patient records within NC HealthConnex by providers at the point of care
• Reports on EHR-integrated participants’ delivery notification messages for additional backup documentation/audit logging

Public Health and Clinical Data Registry Reporting

• Automated reporting to the N.C. Diabetes Specialized Public Health Registry, developed in partnership with the N.C. Division of Public Health
• Automated reporting to the North Carolina Immunization Registry (NCIR) from the provider EHR and query from within the EHR patient records of vaccine history and NCIR recommendations
• Daily automated electronic lab reporting from hospitals to the N.C. Division of Public Health

Moreover, NC HealthConnex supports participating providers in achieving the overarching goals of the Promoting Interoperability Program and other quality programs by:

• Protecting contributed electronic patient health information, per applicable federal standards
• Providing access to a more complete medication and health history from other places of care
• Better informing a provider’s choice of patient education materials or clinical support tools through a longitudinal view of a patient’s health record across care settings statewide

Documentation

While certified EHRs can produce all the necessary reports and documentation to support achievement of the objectives and measures, NC HealthConnex supports providers with care transitions and public health submission documentation for attestation and other specific documentation requests in the case of a state or federal audit.

More Information

For more information about attestation and objectives and measures, visit:

• N.C. Division of Public Health’s Meaningful Use
• U.S. Centers for Medicare and Medicaid Services Promoting Interoperability

For questions or more information about how NC HealthConnex supports providers with Promoting Interoperability requirements, call 919-754-6912.