Proposed 2015 Rule & The Immunization Registry

Proposed 2015 Rule & the Immunization Registry:
Just Testing Will Not Be Sufficient

The proposed rule for 2015 Meaningful Use changes the Immunization Registry measure requirement for EPs and EHs. The proposed rule requires providers to be "in active engagement with a public health agency to submit immunization data and receive immunization forecasts and histories from the public health immunization registry/immunization information system (IIS). If the 2015 proposal for public health measures is finalized as the proposal is written, just testing with the Tennessee Department of Health Immunization Registry will not be sufficient to meet the measure requirement in payment year 2015 and subsequent years.

CMS further defines active engagement as when a provider is in the process of moving towards sending "production data" to a Public Health Agency (PHA) or Clinical Data Registry (CDR) and has applied the concept of "active engagement" to all public health measures.
CMS proposed "active engagement" is demonstrated by:

• Active Engagement Option 1–Completed Registration to Submit Data: The EP, Eligible Hospital, or CAH registered to submit data with the PHA or, where applicable, the CDR to which the information is being submitted; registration was completed within 60 days after the start of the EHR reporting period; and the EP, eligible hospital, or CAH is awaiting an invitation from the PHA or CDR to begin testing and validation.
  
  This option allows providers to meet the measure when the PHA or the CDR has limited resources to initiate the testing and validation process. Providers that have registered in previous years do not need to submit an additional registration to meet this requirement for each EHR reporting period.

• Active Engagement Option 2 - Testing and Validation: The EP, eligible hospital, or CAH is in the process of testing and validation of the electronic submission of data. Providers must respond to requests from the PHA or, where applicable, the CDR within 30 days; failure to respond twice within an EHR reporting period would result in that provider not meeting the measure.

• Active Engagement Option 3 – Production: The EP, eligible hospital, or CAH has completed testing and validation of the electronic submission and is electronically submitting production data to the PHA or CDR.

Please be mindful of these changes.