Friday, May 20, 2011

An FAQ on Exchanging Key Clinical Information

Yesterday, CMS posted an important FAQ clarifying the Meaningful Use requirement to exchange key clinical information.

Since the Standards and Certification final rule does not include any transport standards and no EHR has been tested or certified to comply with any particular transport capability, it was unclear how the CCDs/CCRs produced by certified EHRs should be exchanged as required to attest for meaningful use.

The CMS FAQ suggests that the exchange must be accomplished over an electronic network and not using fixed media:

"No, the use of physical media such as a CD-ROM, a USB or hard drive, or other formats to exchange key clinical information would not utilize the certification capability of certified EHR technology to electronically transmit the information, and therefore would not meet the measure of this objective"

Here's my advice - do an exchange of a single CCD/CCR via a secure website, secure FTP or secure email and you'll be fine.

Although 1) certification focused on content and vocabulary standards, not transport standards and 2) certified EHRs will not be able to tell the difference between a CCD/CCR received via a network or exchanged on media, CMS has given us guidance.   Also, it's a best practice to avoid the use of media for protected health information,  because having clinical data on mobile media is a security risk as noted by the OIG report.


Adrian Gropper said...

Another reason for everyone to implement secure email via Direct Project. It's sponsored by HHS, open source, low cost or no cost. It's designed to be universally accessible, like regular email, so it avoids many of the costs and uncertainties of proprietary or regional systems.

Unknown said...

Thanks for the post. For certification purposes, simply uploading an encrypted file to a secure site (such as Google Docs) has been sufficient.

Merdi Rafiei said...

It would be wise to follow the recommended standards of clinical data exchange using NHIN protocols. I know NHIN is not enforcable, however, we need to start using one common methodology or we will suffer the economic and technological backlashes of having too many disparate ways for doing the same ting (again!), making clinical data crunching and mining a nightmare of epic proportions! I have seen the huge waste of economic and human resources in Re-inventing the Wheel and the Not Invented Here syndromes in the computer industry and am witnessing similar frightening "band-aid" soutions in health care now. Why are we so resistent to using standards? let us not be the next beares of the old joke: "the only good thing about having standards is there are so many to choose from!"