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.