Fall 2019 Newsletter - Call to Action: Promoting Interoperability 2019 & Beyond

By Steven Schulman, MHA, CPHQ Director, Promoting Interoperability Keck Medicine of USC

With the end of CY2019 fast approaching, many eligible hospitals (EH) and eligible providers (EP) are putting forth last minute improvements to increase Promoting Interoperability scores. Promoting Interoperability, for those who aren’t familiar, is the new version of CMS’s Meaningful Use program where CMS regulates the effective use of EHRs, and poor performance can result in negative adjustments being applied to Medicare payments.

Promoting Interoperability is composed of four objectives and six measures, and there are versions for both the inpatient and outpatient settings. The objectives are E-Prescribing, Health Information Exchange, Provider to Patient Exchange, and Public Health & Clinical Data Exchange. The overall goal is to reach or exceed a 50-point minimum, out of a total of 100 points, over a self-selected 90-day reporting window. The focus of this article is the Health Information Exchange (HIE) objective, specifically the Support Electronic Referral Loops by Sending Health Information measure, otherwise known as Send Summary of Care (SOC), a measure underneath the HIE objective and worth 20 points.

The Send SOC measure is part of both the inpatient and outpatient versions of Promoting Interoperability. This measure requires summary of care records to be created and exchanged electronically using Certified Electronic Health Record Technology (CEHRT) for transitions of care and referrals during the reporting period for which your entity is the transitioning or referring entity. This is typically achieved by sending a Continuity of Care Document (CCD) through a Direct address to an external organization. A Direct address functions like an email address, but has additional security specifications set forth by the Office of the National Coordinator (ONC). Once the CCD is received, it is then incorporated into the patient’s chart. While you are able to send CCDs internally, this may result in having duplicate information about a patient in their chart. Consequently, most hospitals and clinics are choosing to send CCDs to external organizations.

Depending on your EHR vendor, the only way to collect an external organization's Direct addresses may be the old fashioned method of picking up the phone and dialing the operator of another clinic or hospital until you are transferred to the correct department. To ease the burden of this process, the Southern California HIMSS community should work together to create a primary means of collecting and exchanging Direct addresses. The more external Direct addresses your organization has, the better you will be able to perform in this measure, meaning you are less likely to incur a negative Medicare adjustment.

To facilitate the exchange of a Direct address, please forward this article to a member of your organization who is involved in achieving Promoting Interoperability attestation. If you are directly working on Promoting Interoperability and would like to find out more on exchanging Direct addresses, please reach out to Steven Schulman, MHA, CPHQ at steven.schulman@med.usc.edu.