Introduction
The Centers for Medicare & Medicaid Services (CMS) have revised existing public health reporting requirements for eligible clinicians (ECs) participating in the Merit-based Incentive Payment System (MIPS) and eligible hospitals (EHs) and critical access hospitals (CAHs) participating in Promoting Interoperability Program (PIP) in the calendar year (CY) 2024.
For calendar year 2024, the Medicare Promoting Interoperability Program for Eligible Hospitals (EH) and Critical Access Hospitals (CAH) requires engagement in four of the existing Public Health and Clinical Data Exchange Objective measures (Syndromic Surveillance Reporting, Immunization Registry Reporting, Electronic Case Reporting, and Electronic Reportable Laboratory Result Reporting), or requesting applicable exclusion(s).
For the ECs participating in the 2024 MIPS, the regulation requires reporting of two measures associated with the Public Health and Clinical Data Exchange Objective: Immunization Registry Reporting, and Electronic Case Reporting.
In CY 2024, there are two options for active engagement for ECs, EHs, and CAHs:
- Option 1 Pre-production and Validation. The eligible participant has completed registration with DPH to submit data and is engaged in testing and validation or waiting for an invitation to begin testing and validation. Please note that there are additional requirements to be met during Option 1 engagement.
- Option 2 Validated Data Production. The eligible participant has completed testing and validation of the electronic submission and its electronically submitting production data (clinical level data) to the PHA or CDR.
The Massachusetts Department of Public Health (MDPH) is actively working with eligible professionals (EPs) and eligible hospitals (EHs) to help them meet 2024 Medicare Promoting Interoperability Program requirements.
Measure 1 – Syndromic Surveillance Reporting
Massachusetts Department of Health (MDPH) accepts syndromic surveillance data from eligible hospital emergency departments and urgent care settings.
Eligible Professionals (EPs) not practicing in a freestanding urgent care facility may claim exclusion for this measure because the MDPH will only accept urgent care syndromic surveillance data from eligible hospitals and freestanding urgent care facilities. Any eligible hospital or critical access hospital (CAH) that does not have an emergency or urgent care department may be excluded from the syndromic surveillance reporting measure.
Successful attestation for this measure requires registration of intent to submit syndromic data within 60 days of start of the reporting period and one of the following: 1) has achieved ongoing submission, 2) is engaged in testing and validation or is awaiting invitation to begin testing and validation.
MDPH participates in the National Syndromic Surveillance Program (NSSP) and utilizes ESSENCE for aggregation and analysis of syndromic surveillance data; data are held in the Amazon Web Services Cloud. The state-wide Health Information Exchange (Mass HIway) serves as the infrastructure to aggregate and send data to the NSSP. This data transmission is in accordance with the standards set forth by the Office of the National Coordinator in order to meet promoting interoperability requirements for syndromic surveillance.
Syndromic surveillance data must comply with the PHIN Messaging Guide for Syndromic Surveillance.
For programmatic information about Syndromic Surveillance and to register intent to submit Syndromic Surveillance data for Promoting Interoperability at syndromic-surveillance@mass.gov.
Measure 2 – Immunization Reporting
The Massachusetts Immunization Information System (MIIS) is available to receive electronic messages from eligible providers for Promoting Interoperability purposes. The MIIS accepts electronic immunization messages (VXU) and bi-directional data exchange (QBP/RSP) in the HL7 2.5.1 format from certified electronic health record systems. Detailed technical specifications and other information for electronically exchanging data with the MIIS are available on the MIIS homepage via the link Information for Providers. Additional technical information is available upon request.
The statewide Health Information Exchange (Mass HIway) will serve as the infrastructure to accept data from existing EHR systems in real time, eliminating the burden of duplicate entry into your system and into MIIS. The Mass HIway accepts HL7 version 2.5.1 messages and fulfills the applicable Promoting Interoperability measure. Learn about how to enroll in the Mass HIway at https://masshiway.net/Enroll.
Please note that pursuant to M.G.L. Chapter 111, Section 24M all licensed health care providers that administer immunizations are required to report immunization data to the MIIS.
For more information, and to formally register intent to submit immunization data, please contact the MIIS Help Desk: (617) 983-4335 or miishelpdesk@mass.gov.
Measure 3 – Electronic Case Reporting (eCR)
Reporting of diseases dangerous to the public by clinicians is mandated by 105 CMR 300.000 (Reportable Diseases Surveillance and Isolation Requirements). The Massachusetts Department of Public Health is ready to accept electronic case reports.
MDPH uses the HL7 electronic initial case report (eICR) standards (R1.1 and R3) for electronic case reporting (eCR), and to support CMS Promoting Interoperability standards for eCR. We will require the use of the Association of Public Health Laboratories’ Informatics Messaging System (AIMS) and the Reportable Condition Knowledge Management System (RCKMS) for reporting.
MDPH has been assisting selected providers to transmit EHR data on reportable conditions via the Electronic medical record Support for Public Health (ESP) system, as summarized in the table Overview of DPH Reporting Requirements of ESP Reporting Sufficiency. While these reports do not fully replace eCR submissions, Eligible Providers using ESP will meet eCR Promoting Interoperability requirements for 2024. Reports sent via this format are currently being upgraded to comply with the eCR HL7 messaging standards.
Infectious disease reporting consistent with these standards will eventually significantly reduce manual reporting burdens.
For more information, please contact ELR.CDSupport@mass.gov.
Measure 4 – Electronic Laboratory Reporting (ELR)
Electronic Laboratory Reporting is a secure, automated mechanism for the reporting of laboratory and patient information by hospitals and commercial laboratories. ELR is mandated in accordance with 105 CMR 300.170 (Laboratory Findings Indicative of Infectious Disease reportable Directly to the Department by Laboratories).
The Massachusetts Health Information Reporting Portal (HIRP) is available to receive electronic messages from eligible providers for Promoting Interoperability purposes. The HIRP accepts electronic laboratory result reports in the HL7 2.5.1 format from certified electronic health record systems. Additional technical information is available upon request.
Please review Infectious Disease Reporting and Regulations for Health Care Providers and Laboratories to see if your facility is exempt from reporting ELR performed on-site.
MDPH will accept HL7 2.5.1 ELR via the statewide Health Information Exchange (Mass HIway) or SFTP.
For more information, please contact ELR.CDSupport@mass.gov.
Measure 5 – Antimicrobial Use and Resistance (AUR) Surveillance
Eligible hospitals and CAHs must attest to being in active engagement with CDC’s NHSN to submit AUR data for the EHR reporting period, or else claim an applicable exclusion. Further, to meet the CMS PI Program requirement, facilities must use CEHRT updated to meet 2015 Edition Cures Update criteria, including criteria at 45 CFR 170.315 (f)(6).
Refer to the CMS Promoting Interoperability Program webpages for additional information, including CY-specific submission requirements.
Public Health Registry (Optional)
Cancer Registry
The Public Health Registry and Clinical Data Registry Reporting objective includes a measure related to reporting to Public Health Registry, which includes Cancer Reporting by EPs only to State Cancer Registries.
The Massachusetts Cancer Registry supports cancer reporting from ambulatory providers/EPs. Cancer reporting is part of the Centers for Medicare and Medicaid Services Promoting Interoperability Programs. The CDC provides an overview on reporting to Public Health Registries in Public Health Data Interoperability (cdc.gov).
An EHR system must meet 2015 certification criteria 170.314(F)(4) Transmission to Cancer Registries to be considered Certified EHR Technology for cancer reporting. For more information, please review the Implementation Guide.
If you diagnose and/or treat cancer patients in an ambulatory setting in Massachusetts and would like to report cancer cases for Promoting Interoperability, register with the Massachusetts Cancer Registry by the 60th day of your reporting period. You must have Certified EHR Technology that can produce cancer CDA messages. For registration or questions, please contact the Cancer Registry’s Registry’s Operations Manager, Nancy Klein, at nancy.klein@mass.gov.
Clinical Data Registry Reporting (Optional)
The Massachusetts Department of Public Health does not currently support any Clinical Data Registries for Meaningful Use purposes.
Mass HIway
The Massachusetts Department of Health (MDPH) and the Mass HIway have partnered to transition all public health data reporting to the secure, statewide health information exchange (HIE). The key goals of this are to automate the data import process, simplify the administrative process, and remove as many manual interventions on the data as possible. This can also reduce cost for providers by maintaining fewer reporting interfaces. For more information about the Mass HIway and how to enroll, please visit the Massachusetts Health Information HIway website.
This information is provided by the Massachusetts Department of Public Health.