Medicaid Ehr Incentive Program Health Information Exchange - Objective Stage 3 - Centers For Medicare And Medicaid Services Page 5

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In instances where a “third party organization that plays a role in determining the next provider of care and
ultimately delivers the summary of care document” is involved, the service the third party provides does not
have to be certified for the transmission to be counted in the numerator for measure 2. There are also no
specific requirements around the technical standards or methods by which the third party delivers the summary
of care document to the receiving provider (e.g., SOAP, secure email, fax).
Acceptable Electronic Transmission Methods
Examples of acceptable transmission methods include secure email, Health Information Service Provider
(HISP), query-based exchange or use of third party HIE. There are many other options in addition to the
examples listed, as well as opportunities for developers and vendors to utilize innovation and creativity. The
provider must ensure that the transmission methods are in compliance with HIPAA requirements.
Note: Faxing in general is not acceptable since it is not in C-CDA format. It is only acceptable when a third
party is used to transmit the summary of care record and they must convert the transmission to fax because
that is the only way the receiving provider can accept the transmission. Additionally, the conversion to fax by
the third party must not be a default approach.
To count in the numerator, the sending provider must have reasonable certainty of receipt of the summary of
care document. This means that a ‘‘push’’ to an HIE, which might be queried by the recipient, is insufficient.
Instead, the referring provider must have confirmation that a query was made to count the action toward the
measure. (This could be a call to the receiving provider or email confirmation from the HIE itself in instances
where a third party is used.) The exchange must comply with the privacy and security protocols for ePHI under
HIPAA.
An EP and eligible hospital must use the capabilities and standards of as defined in
CEHRT at §
495.4.
For More Information
Visit the
CMS EHR Incentive Programs website
to learn more about the requirements for the EHR Incentive
Programs.
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