Since CMS finalized the modifications to the Meaningful Use program in October 2015, providers have been scrambling to find information on public health reporting options.
While some providers are already connected to their specialty registries or to state and local immunization registries, many Eligible Providers have been without options for meeting this requirement. There is no up-to-date source of Specialized Registries and their offerings.
Meeting this requirement means being in "active engagement" with a Specialized Registry within the first 60 days of the Measurement Year. The original deadline was February 29 for the 2016 Measurement Year under Meaningful Use. However, CMS just issued updated instructions, essentially stating that a provider may register intent to report to a Specialized Registry after the initial 60 days if the registry declares readiness at any point in 2016. See CMS FAQ14393 for specific language.
What is a Specialized Registry?
CMS has incorporated the use of an aggregated patient database technology in several of its Value-Based Health Care programs: Registry Reporting for PQRS, the Qualified Clinical Data Registry for measure development and reporting, and the Specialized Registry and Clinical Data Registry for Meaningful Use. While there isn't great specificity about what a Specialized Registry is from the rules, it is clear that it must be helpful to patients. This is what the rule describes:
• The Specialized Registry must collect production data from the providers' EHR, which can be done in a variety of ways. However, the Specialized Registry is not responsible for reporting providers' performance on the Clinical Quality Measures (CQMs) to Medicare.
• Reporting to a Specialized Registry will satisfy this MU Public Health Reporting objective.
• The Specialized Registry appears likely to become a Clinical Data Registry, enabled under a separate provision of the Public Health Reporting for Stage 3 MU starting in 2017 (optional) and required in 2018. CMS specifically describes the benefit of having "outcomes over time" as the benefit of the CDR.
Challenges to Satisfying the Public Health Reporting Requirement
In requiring public health reporting to Specialized Registries, CMS has allowed plenty of exclusions for providers during this transitional period. These respond to several concerns about public health reporting, including the newness of the requirements and the number of registries available for reporting. Even governmental agencies' capability for acceptance of immunizations and syndromic surveillance data is not universal throughout the country.
But the Specialized Registry, which up until now has had no official place in public health reporting, is even murkier. CMS has neither created an official definition for a Specialized Registry nor any information on which Specialized Registries exist and are available for reporting. The latest Meaningful Use Modifications indicate, however, that the Specialized Registry will later be a Qualified Clinical Data Registry (QCDR), with the purpose of tracking and improving long-term outcomes.
Most current QCDRs and Specialized Registries are, in fact, established under single specialties or organized to collect data on particular clinical conditions, and are therefore only available for reporting by those specialty providers. But multi-specialty groups, in particular, will need to be able to see all their data benchmarked in a single interface to achieve performance improvement. In an environment already fragmented by exclusive standards, the all-specialty Specialized Registry will provide a vehicle for a comprehensive approach to improving outcomes, which spans all settings of care and all professionals.
Theresa Hush is co-founder and CEO of ICLOPS, LLC, a Qualified Clinical Data Registry founded in 2002 that pairs tailored technology with a supported discovery process to improve patient health. ICLOPS's four Specialized Registries, opened in February 2016, perform analyses and tracking of patient outcomes across all specialties, and lay the foundation for multi-specialty groups' efforts to improve performance and research efficacy of interventions.
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