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.