CMS Exclusions Update

At Greenway Health, service is the main thing, and part of that pledge is to provide our customers with the most up-to-date and accurate regulatory guidance possible. We recently contacted you about meaningful use Stage 2’s Public Health Reporting objective. Prior to Feb. 25, CMS guidance stated that eligible professionals (EPs) had to actively engage in two public health registries by Feb. 29, 2016, for the 2016 program year. Three registry types were available: immunization, specialty and syndromic surveillance registries. Unlike in 2015, CMS released guidance that the alternate exclusions did not apply for 2016.[1] On Feb. 25, 2016, four days before the active engagement deadline, CMS released new guidance allowing EPs to use alternate exclusions for 2016 reporting as well.[2] EPs can now claim alternate exclusions for syndromic surveillance reporting and specialized registry reporting.[3] Below is an excerpt from a CMS FAQ: “We will allow providers to claim an alternate exclusion for the Public Health Reporting measure(s) which might require the acquisition of additional technologies the providers did not previously have or did not previously intend to include in their activities for meaningful use … EPs … [m]ay claim an Alternate Exclusion for Measure 2 and Measure 3 (Syndromic Surveillance and Specialized Registry Reporting).”[4] As noted, CMS did not intend to force providers to buy and implement new technologies they did not plan for and released this new guidance to meet its intended goal.[5] Our interpretation of CMS’s new guidance is that if you had planned only to connect to an immunization registry to meet Stage 2’s Public Health Reporting objective, EPs can now do so by claiming alternate exclusions for syndromic surveillance and specialty registry reporting. Greenway Health understands that many customers have already made plans and purchases based on CMS’s prior guidance. While meaningful use and other government programs are subject to frequent changes, sometimes shortly before regulatory deadlines, we are here to serve and support you in this dynamic industry. If you believe you qualify for the above exclusions for 2016, we want to ensure you have the flexibility to adjust your meaningful use strategy in light of the recent changes. To modify an order you’ve placed, based on CMS’s former guidance, please email with the subject line “Specialty Registry Reporting” by March 14, 2016.

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