Interfaces/Electronic Transmissions

I have an engine that is owned and maintained by my IT staff. Can I configure the interfaces required for Meaningful Use or do I have to purchase an Evident-configured interface?

The universal feeds do not include the internal mapping and/or translations utilized to meet the implementation guidelines/criteria outlined in the Meaningful Use objectives and therefore cannot be used for Meaningful Use attestation.

How far in advance do I need to place orders for required interfaces?

Orders need to be placed as soon as possible. The minimum lead time for all interface orders is 90 days. Interfaces must be purchased in production prior to the start of the Meaningful Use reporting period.

My facility utilizes a separate product for patient access to our website for accounting needs and well-being instructions. Can the Thrive Patient Portal be linked to this portal product for the View/Download/Transmit objective that Evident plans to implement through the portal?

No, the email triggers, statistic tracking, etc. require use of the Thrive Patient Portal to meet the View, Download & Transmit objective.

If my public health agency is unable to accept the reporting data in an HL7 v2.5.1 message, or requires validation of multiple transmissions before allowing my facility to move to a production status, can Evident provide a letter of exclusion for that objective?

Only the public health agencies or an authorized entity of the state can provide exemption or exclusion status. This documentation must be stored with the rest of your attestation information for audit purposes. It is also recommended that the facility provide a copy of the exclusion to Evident for audit/tracking purposes.

We participate in a Regional Health Information Organization (RHIO) and they have the ability to submit public health reporting data for the RHIO participants. Can I use the interface to the RHIO to satisfy all the public health reporting objectives?

A Health Information Exchange (HIE) or Regional Health Information Organization (RHIO) is not required to certify for Meaningful Use and may not meet the federal requirements that are included in the Meaningful Use audits. Keep in mind that the interface is typically developed per the HIE/RHIO specifications, not the federal guidelines. Given this, Evident recommends that you confirm with the RHIO/HIE, and with the state to whom the reportable data is sent, that use of the HIE/RHIO for attestation to the public health reporting objectives will comply with federal regulations and standards and ensure you pass an Meaningful Use audit should one be issued for your facility.

Do I have to have an interface for Quality Measures in Stage 2 of Meaningful Use?

No – Initially, CMS indicated plans to require electronic submissions for Clinical Quality Measure (CQM) data but no specifications were provided and the electronic submission requirement was later retracted. The current process for submitting Quality Measures remains acceptable. More information is available on the CMS website.

How can I make sure the Syndromic Surveillance interface includes all the required data for public health reporting?

Syndromic Surveillance interfaces typically send demographic data as well as the patient’s chief complaint. It is Evident’s recommendation that each facility transition the chief complaint field in the Census tab to a required field, thereby ensuring it’s included with every registration.

I read that my lab results must be in a discrete structured format. How can I confirm the format if I do not have access to the interface messages? With this requirement, do you anticipate any changes in the way reference labs deliver results? For example we receive a lot of results as HL7 "comments" or “blurbs of text” – is there set criteria to determine how structured "structured data" really is?

The term “structured data” is somewhat ambiguous but the criteria included in the Laboratory Results Interface (LRI) and Electronic Laboratory Reporting (ELR) implementation guidelines from ONC define use of HL7 v2.5.1 with incorporation of universal code sets per value reported.

If the comments are received as structured data per the implementation guidelines in the Thrive System, there is no need for changes to the reference lab result delivery. If the comments are not received as structured data, the reference lab result format could impede the facility’s ability to achieve Meaningful Use.

Any results entered into Thrive manually via the Thrive Laboratory Information System (LIS) application are stored and transmitted out in a discrete format. All results that are received from external entities will require additional examination. Evident has performed a general review of current interface configurations and identified that many vendors are not transmitting all results in a structured format. To ensure your laboratory interfaces meet the requirements, please contact your Reference Lab (or LIS if you do not use the Thrive LIS application) vendor and ask the following:

• Do you have the ability to transmit results to Evident in the discrete/structured format for ALL laboratory results – including micro/culture results – as outlined in the ELR objective inclusive of the LOINC and SNOMED-CT data sets?
• Do you require a product upgrade to transmit all results in a structured format?
• What is the timeline for implementation and subsequently validation testing?

Please note that vendor modifications will necessitate changes in the Thrive System as well and validation testing is crucial to ensuring accurate reporting of the results. Evident will require a lead time of 90 days to modify an existing interface so it’s important to contact us as soon as you determine a need to change an inbound lab results interface.

Do third party vendors that send data to the Thrive System have to be Meaningful Use certified?

No, the third party systems do not have to be certified since the Thrive EHR is the certified product for attestation. However, if Thrive is using data received from a third party system to meet interoperability requirements, all data elements and formatting must comply with the implementation guidelines needed to attest. For instance, in order for Thrive to transmit lab results to the public health agencies in the manner outlined in the implementation guide, ie: structured and with LOINC/SNOMED-CT, that information must be received from any laboratory vendor that sends results to the HIS.

Can lab results be scanned into the EHR and be acceptable for structured data and submission for public health reporting (ELR)?

Please reference the question/answer regarding structure or discrete format for more information on Evident compliance with the Meaningful Use objective requirements associated with Electronic Laboratory Reporting (ELR). Scanned documents are blurbs of text that cannot be parsed and therefore do not meet the requirements and are not included in the Thrive transmissions for public health reporting.

From Section 170 page 44602 of 45 CFR, the ONC final rule page:

“We recognize that Certified EHR Technology may also store health information in scanned documents, images, and other non-interoperable non-computable formats and, consequently, do not expect Certified EHR Technology to be capable of reading or accessing the information in these other formats.”

Based on this statement and Evident specifications, a paper report that is scanned and attached will not be considered structured data. 

I have a third party vendor that sends data to Evident in HL7 v2.3 and this data will be included in what is transmitted for public health reporting. Does that vendor have to start sending the data in HL7 v2.5.1 or can we up-convert the current data stream to meet the criteria that requires HL7 v2.5.1 for interfaces?

Technically, yes. We can convert HL7 v2.3 to v2.5.1 but all of the required data elements must be included in the v2.3 message for it to be successfully updated to the public health agency.

I have a Microbiology analyzer in my lab. Is there anything I need to do to be sure these results are in a discrete format?

Most of the analyzers do not incorporate the universal coding (LOINC and SNOMED CT) that is required for Meaningful Use reporting. However, Evident can incorporate the required elements and format with the use of the Thrive Laboratory Information System (LIS) Infection Control application. Evident assistance with this is necessary as the interface program to initiate the use of Infection Control must be changed by Evident personnel. Each facility will be required to complete the entries in the Infection Control application and item setup for this option to be functional.

Can I create a hyperlink in the Thrive ChartLink application to a third party PACS system and use that to meet the menu objective for accessing the image from the EHR?

No, the criteria for this objective specifies access to the patient and associated diagnostic test(s) which requires the implementation of a URL interface to allow the launch point at the order.

Do all of my “public health” interfaces have to be successful ongoing submissions to my public health agency for Meaningful Use Stage 2?

Yes, all public health interfaces must be successful ongoing submissions from the certified EHR to the registry for the entire reporting period. (Note: some exclusions apply). If your state is exempt, your state will need to provide your facility with a letter of exemption.

With the increased demand for EHR integration, what is Evident doing to facilitate this process between third party systems and the Thrive system?

Evident is doing everything we can to encourage interoperability opportunities, to accelerate development and to deploy our piece of the integration progression in a timely manner. Every interface requires the coordination of three different organizations: Evident (the EHR vendor), the third party vendor and the facility, along with the various timelines of each group. In addition, it is the responsibility of the facility to validate every interface. While it may only take a week or two to actually deploy the interface, the testing and validation process can take much longer.

My facility uses a reference laboratory for a portion of our microbiology testing and the results from this reference lab are not compliant with Meaningful Use. If state law requires that all reportable lab results performed by my hospital or received from my reference lab must be reported, does that mean that my facility has to report all the results to meet Meaningful Use?

Technically, the intent with public health reporting is that all reportable conditions will be included. It’s important to reiterate that reporting to the public health agency (PHA) is separate from Meaningful Use.  All public health reporting should comply with the state/jurisdictional requirements. To satisfy the public health reporting objectives for Meaningful Use, the data must be transmitted by a certified vendor and in the format detailed in the standards criteria associated with the objective.

Keep in mind that the Meaningful Use public health objectives do not have a percentage-based measurement. A percentage-based measure would only be applicable to those facilities, Eligible Hospitals (EH) and Critical Access Hospitals (CAH), engaged in ongoing submission. There are four different conditions to which your facility may attest to public health objectives under the umbrella of ongoing submission for Stage 2:

• The EH/CAH already achieved ongoing submission for an EHR reporting period in a prior year and it has continued throughout the current EHR reporting period.
• The EH/CAH has registered intent to initiate ongoing submission with the public health agency (PHA) by the deadline (within 60 days of the start of the EHR reporting period) and ongoing submission was achieved.
• The EH/CAH has registered intent to initiate ongoing submission with the PHA by the deadline and they are engaged in testing and validation.
• The EH/CAH has registered intent to initiate ongoing submission with the PHA by the deadline and they are awaiting invitation to begin onboarding.

CMS describes successful ongoing submission as the electronic submission of reportable data during the normal course of a provider’s operations. This is not to say all data that is reportable is sent to the PHA. A provider who is submitting any reportable data during their normal course of their operations is engaged in ongoing submission. Again, to successfully attest to Meaningful Use, a single test that is consistently submitted (when positive) as prescribed by the Meaningful Use objective, meets the measure.

It is in your facility’s best interest to work with your reference lab vendor to provide results that are Meaningful Use compliant so that all results can be reported to the PHA in the required format.

For more information, please review the ONC Options to Meet Electronic Laboratory Reporting.

My facility does not test any reportable conditions in house – all testing is done by a reference lab. Our state requires that both the performing lab and the ordering facility report results with reportable conditions. Since the reference lab we use is a commercial reference lab and does not have a certified product, they cannot submit on our behalf; and we don’t have an interface that includes all the fields that Meaningful Use requires. How can my facility meet Meaningful Use?

First, keep in mind that on-going submissions is the goal but the objective can be met without reaching a production status with your public health agency. For Stage 1, submission of a failed test message will satisfy the objective; for Stage 2 registration and onboarding (see detailed notes below) satisfy the objective.  

It is important to note that if jurisdictional (aka: state) regulations require the ordering facility to report results from their reference laboratory and your facility does not perform any lab testing for reportable conditions, then the facility that ordered the lab testing [Eligible Hospital (EH) or Critical Access Hospital (CAH)] would be required to submit reference lab performed reportable lab results to public health using CEHRT and would not be excluded.

There are four criteria for which an EH/CAH may attest to public health objectives that were established by CMS under the umbrella of ongoing submission for Stage 2:

• The EH/CAH already achieved ongoing submission for an EHR reporting period in a prior year and it has continued throughout the current EHR reporting period.
• The EH/CAH has registered intent to initiate ongoing submission with the public health agency (PHA) by the deadline (within 60 days of the start of the EHR reporting period) and ongoing submission was achieved.
• The EH/CAH has registered intent to initiate ongoing submission with the PHA by the deadline and they are engaged in testing and validation.
• The EH/CAH has registered intent to initiate ongoing submission with the PHA by the deadline and they are awaiting invitation to begin onboarding. 

The only way the measure will not be met is if the provider:

• Fails to register their intent by the deadline; or
• Fails to participate in the onboarding process as demonstrated by failure to respond to the PHA written requests for action within 30 days on two separate occasions.

Therefore, your facility can meet Meaningful Use as long as you have registered your intent to initiate ongoing submission with the public health agency (by the deadline) and participate in the onboarding process as outlined by your state.

For more information, please review the ONC Options to Meet Electronic Laboratory Reporting. 

When a patient is registered in Thrive and upon inquiry they respond that they have not received any immunizations since their last visit, should I document that no vaccine was administered in the immunizations menu?

No. If the patient has not had any vaccines administered since their last visit, no new entry should be added to the immunization entry menu. Each entry made in this menu creates a record that is subsequently sent to your immunization registry via the public health interface. Each record should contain the vaccine that was received by the patient, or an explanation as to why the patient did not receive a vaccination. For example, CVX code 998 is utilized in the CPSI software to document that no vaccine was administered due to evidence of immunity. Evidence of immunity indicates that a person has plausible evidence that they have already developed immunity to a particular disease and further immunization against the disease is not likely to provide benefit. When a user selects "No vaccine administered" (CVX 998) in immunization entry, the Evidence of Immunity field should be addressed to attach an applicable SNOMED code and description to indicate that a patient is immune to a specific disease.

In summary, if the patient has not received any vaccines at any other facility since their last visit at your facility, no entry should be made in the immunization entry menu.

For outside reference labs that do the reportable lab results, what is the hospital’s obligation to make sure that the reference lab is capable of doing this and is actually doing it? Our reference lab was not at all clear whether or not they can do this, or if they even have plans to do so.

The public health agency should provide documentation either on their website or as part of your onboarding documentation as to whether they require dual or singular reporting. Agencies that require dual reporting expect both the ordering and performing facilities to submit reportable results. Agencies that require reporting from the performing lab only will establish the required transmission protocols with the reference lab(s) as reportable results is already a requirement for performing labs. Therefore, no further follow-up is required on your part. However, it is Evident’s recommendation that you keep a copy of the agency’s expectations for reporting (screenshot, specifications, email notification) in your Meaningful Use audit folder. Additionally, please keep in mind that any tests performed in-house that include reportable results must be submitted by your facility; the reference lab is only responsible for reporting the reportable results for tests they perform.

If my interface for public health reporting is ‘on hold’ or ‘in the queue’ with the state agency, what exclusion option do I select for my Stage 2 attestation?

You should only select an exclusion option if your state agency has provided your facility with a letter of exclusion/exemption. If your facility has completed the state-required registration/onboarding and are waiting to begin implementation, you should select ‘Yes’ to attest. Keep in mind that the attestation requirements included with the public health reporting objectives include registration with intent to initiate ongoing submissions within 60 days of the start of the reporting period as well as the full/ongoing submissions.

My hospital has an interface with a third party clinic vendor where orders are sent to the hospital and the results are returned to the physician’s clinic. We plan to use this for the ‘Incorporate Clinical Lab Tests’ objective. Does the physician in the clinic have to sign the orders in Thrive for these orders to meet Meaningful Use requirements and/or legal signature requirements on orders?

No, the Meaningful Use criteria surrounding this objective do not specify inclusion of the physician signature in the order message. Additionally, 42 CFR 410 indicates documentation by the treating physician (i.e.: in the summary of care/progress note) that he/she intended for the test to be performed will satisfy the authorization requirement without the need for the signature of the ordering physician. The industry standard on electronic orders is to include the ordering physician in the HL7 transaction as acceptable authorization for the test to be performed.