Stage 1 Menu Set Objective for Eligible Hospitals or Critical Access Hospitals (CAHs) to Submit Lab Results

Meaningful Use Requirements - Objectives and Measures

Eligible providers may choose at least one of two public health objectives and measures from a menu set to meet the meaningful use requirements in Stage 1. These objectives include submitting electronic immunization information to immunization registries or immunization information systems, and/or submitting electronic syndromic surveillance data to public health agencies. Eligible hospitals must also choose at least one public health objective from the menu set which includes the two objectives previously listed and/or submitting electronic laboratory results to public health agencies. See eHealth in Public Health for more information about meaningful use.

In order to fulfill the public health objective of capability to submit lab results to a public health agency, hospitals must comply with two federal regulations:

I. Centers for Medicare and Medicaid Services Final Rules EHR Incentive 495.6(g)(9), Paragraph Citation 75 FR Page 44570 (Also see CMS Final Rules for the EHR Incentive Program).

Objective: Capability to submit electronic data on reportable (as required by State or local law) lab results to public health agencies and actual submission according to applicable law and practice.

Measure: Performed at least one test of certified EHR technology’s capacity to provide electronic submission of reportable lab results to public health agencies and follow-up submission if the test is successful (unless none of the public health agencies to which an eligible hospital or CAH submits such information has the capacity to receive the information electronically).

Exclusion for Eligible Hospitals and CAHs: Exclusion in accordance with paragraph (b)(2) of this section. No public health agency to which the eligible hospital or CAH submits such information has the capacity to receive the information electronically.

II. Office of National Coordinator Final Rules Health Information Technology Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology (75 FR 44590)

The Electronic Health Record (EHR) System or module submitting the lab data must also be certified using the following criteria and standards:

Summary of Laboratory Reporting Standards, Implementation Specifications and Certification Criteria

Certification Criterion	Electronic Health Record (EHR)Technology:
Certification Criterion	Content Exchange Standards and Implementation Specifications		Message Vocabulary
Final Rule Text: § 170.306(g). Reportable lab results. Electronically record, modify, retrieve, and submit reportable clinical lab results in accordance with the standard (and applicable implementation specifications) specified in § 170.205(c) and, at a minimum, the version of the standard specified in § 170.207(c).	HL7 2.5.1	HL7 Version 2.5.1 Implementation Guide: Electronic Laboratory Reporting to Public Health, Release 1 (Available for purchase at www.HL7.org)	LOINC version 2.27

Frequently Asked Questions Regarding Electronic Lab Result Submission

What type of lab test results should we submit?

CMS Final Rules state: “Capability to submit electronic data on reportable (as required by State or local law) lab results to public health agencies and actual submission according to applicable law and practice.” Therefore, reportable lab results include:

Infectious Diseases: See Reportable Infectious Diseases: Reporting by Laboratories (PDF)from the Division of Communicable Disease Control.
Cancer: Please see the Pathology Laboratory Reporting Guidelines (PDF) and Laboratory Reporting Standards (PDF) from the California Cancer Registry.
Blood Lead Lab Results: Please see relevant statutes cited by the Childhood Lead Poisoning Prevention Branch.

Since there are privacy and security concerns, can I submit a test with “dummy” data instead of “real” lab results from an actual patient?

CMS Final Rules state: “While the use of test patient information may increase the risk that the system will not be testing to its full capability, given the privacy and security concerns surrounding the transmission of actual patient information we do not require it for the purposes of a test. Therefore, the use of test information about a fictional patient that would be identical in form to what would be sent about an actual patient would satisfy this objective. However, we note that this is one of the objectives that a State may modify as discussed previously in this section. Therefore, more stringent requirements may be established for EPs and eligible hospitals under the Medicaid program in states where this capability exists.” (75 FR Page 44360)

California has not modified any requirements to date; thus, test information is acceptable for Stage 1 of Meaningful Use.

When can I submit the lab results to the public health agency?

CMS Final Rules state: “The testing could occur prior to the beginning of the EHR reporting period, but must occur prior to the end of the EHR reporting period.” (75 FR Page 44360)

The CMS website lists Meaningful Use reporting timelines and other important dates.

For Medi-Cal, see the Department of Health Care Services (DHCS) website.

To whom do I submit the lab results?

CMS Final Rules state: “Eligible hospitals and CAHs should attempt to identify one public health agency with whom to conduct a test of the submission of electronic data... If the test is successful, then the eligible hospital or CAH should institute regular reporting to that entity according to applicable law and practice.” (75 FR Page 44360)

CalREDIE Electronic Lab Reporting (ELR)

California Reportable Disease Information Exchange Electronic Lab Reporting (CalREDIE ELR) allows healthcare/lab facilities to comply with public health reporting requirements for reportable diseases through an automated, secure communication process. Submitting facilities extract reportable laboratory result data from their information systems and construct a standard formatted message to send to the state and participating local public health agencies through CalREDIE.

Entities sending laboratory results electronically to CalREDIE jurisdictions may satisfy the ELR measure of Meaningful Use. Please see this CalREDIE map and CalREDIE list.

For information on reporting laboratory results in jurisdictions not using CalREDIE, please consult with the local health department.

Please consult the CalREDIE ELR page for more information, including a link to the CalREDIE ELR Companion Guide.

For general questions regarding CalREDIE ELR, please contact the CalREDIE staff at elr@cdph.ca.gov.

At this time, the California Cancer Registry and the lead reporting and surveillance system (RASSCLE II) are not able to receive HL7 version 2.5.1 messages.

What do I do if my LHD is not able to receive my data?

CMS Final Rules state: “We agree that many areas of the country currently lack the infrastructure to support the electronic exchange of information. As meaningful use seeks to ensure certified EHR technology has the capability to submit electronic data to public health agencies, we only require a single test if a receiving entity is available and follow up submission only if that test is successful.” (75 FR Page 44360)

Exclusions for eligible hospitals and CAHs would apply. See Section 495.6 Meaningful use objectives and measures for EPs, eligible hospitals, and CAHs below. (FR Pages 44566-70)

(b) Stage 1 criteria for eligible hospitals and CAHs—

(1) General rule regarding Stage 1 criteria for meaningful use for eligible hospitals or CAHs. Except as specified in paragraphs (b)(2)
and (b)(3) of this section, eligible hospitals and CAHs must meet all objectives and associated measures of the Stage 1 criteria specified in paragraph (f) of this section and five objectives of the eligible hospital’s or CAH’s choice from paragraph (g) of this section to meet the definition of a meaningful EHR user.

(2) Exclusions for non-applicable objectives. (i) An eligible hospital or CAH may exclude a particular objective that includes an option for exclusion contained in paragraphs (f) or (g) of this section, if the hospital meets all of the following requirements:

(A) The hospital meets the criteria in the applicable objective that would permit an exclusion.

(B) The hospital so attests. (ii) An exclusion will reduce (by the number of exclusions received) the number of objectives that would otherwise apply. For example, an eligible hospital that is excluded from one of the objectives in paragraph (g) of this section must meet four (and not five) objectives of the hospital’s choice from such paragraph to meet the definition of a meaningful EHR user.

Where can I test my lab data submission?

We recommend that your hospital use the Center for Disease Control PHIN Message Quality Framework (MQF) to assist in testing your initial lab data submission.

In support of CalREDIE ELR, CDPH is developing a message analyzer specific to California Requirements. When completed, this analyzer will be available from the CalREDIE ELR page.

How do I attest for meeting Meaningful Use?

CMS and Medi-Cal will accept a yes/no attestation to verify that eligible hospitals or CAHs have fulfilled the objective and measure of submitting electronic lab results in the the first year reporting period. For auditing purposes, CMS also states that “all providers attesting to receive an EHR incentive payment for either Medicare or Medicaid EHR Incentive Programs should retain ALL relevant supporting documentation (in either paper or electronic format used in the completion of the Attestation Module responses). Documentation to support the attestation should be retained for six years post-attestation. Documentation to support payment calculations (such as cost report data) should continue to follow the current documentation retention processes.”

For hospitals in jurisdictions where the LHD can accept messages, please contact the LHD for proper documentation.

For hospitals in jurisdictions where the LHD cannot accept messages, CDPH recommends printing the California Public Health Capacity to Receive Reportable Electronic Lab Results (PDF) Opens a new browser window document. This list will be continually updated as LHDs acquire the capability to accept messages. The list may serve as supporting documentation that the LHD in your jurisdiction could not accept messages at the time your lab message was sent.

It is important that you obtain the most updated list from this website to ensure you do not have an outdated list in your audit documentation.

Medicare Hospitals and CAHs

Visit the CMS website for more information on attestation.
CMS has prepared a Meaningful Use Attestation Calculator to assist you prior to submitting your attestation to see if you would be able to meet all of the necessary measures to successfully demonstrate meaningful use and qualify for an EHR incentive payment.
Also, review the CMS Attestation User Guide (PDF, 6.4 MB)for hospitals and CAHs to provide step-by-step instructions for login and completing attestation. For the public health objectives, see pages 19 to 23 of the user guide.

Medi-Cal Hospitals and Critical Access Hospitals

Visit the DHCS website for more information on attestation.
DHCS has also prepared an Attestation Workbook (Excel)to assist you in preparing for attestation.

To whom do I send my attestation?

Medicare providers and hospitals must demonstrate Meaningful Use through the CMS web-based Registration and Attestation System.

Medi-Cal providers and hospitals, please submit your attestation to the Department of Health Care Services.

When do I attest to Meaningful Use?

Start and end dates to attest for the EHR Incentive Program are different for Medicare versus Medi-Cal programs and hospitals versus providers. Please see important dates listed by CMS below:

April 18, 2011 – Attestation for the Medicare EHR Incentive Program begins.
November 30, 2011 – Last day for eligible hospitals and critical access hospitals to register and attest to receive an Incentive Payment for Federal fiscal year (FY) 2011.
February 29, 2012 – Last day for eligible professionals to register and attest to receive an Incentive Payment for calendar year (CY) 2011.

The CMS website lists Meaningful Use reporting timelines and other important dates.

I have heard that States can change the requirements for submitting lab results as an objective for the Medi-Cal Incentive Program. Has California changed any requirements for submission of lab results?

While States do have the option to modify requirements for public health objectives/measures such as submitting electronic lab results under the Medi-Cal Incentive Program, California has not modified any requirements to date.

CMS Final Rules state: “State could specify the standards-based means of transmission and/or the destination of this data. States would also be permitted to request CMS approval to include this objective in the core list for all and eligible hospitals. The justification for this request in their State Medicaid HIT Plan should address any potential barriers for providers in achieving this objective.” (75 FR Page 44365)

Additional Resources and FAQs Regarding Meaningful Use:

Office of the National Coordinator for Health Information Technology (ONC): ONC is at the forefront of the administration’s health IT efforts and is a resource to the entire health system to support the adoption of health information technology and the promotion of nationwide health information exchange to improve health care.

ONC Regulations Frequently Asked Questions

Centers for Medicare and Medicaid Services (CMS): The CMS has oversees the Medicare and Medicaid EHR Incentive Programs which provide a financial incentive for the "meaningful use" of certified EHR technology to achieve health and efficiency goals.

CMS Frequently Asked Questions

The Centers for Disease Control and Prevention (CDC): The CDC is engaged in EHR policy decisions to improve care for individuals and provide leadership to leverage Meaningful Use for public health. Currently, we are collaborating with and providing input to ONC and CMS for consideration of public health priorities within Meaningful Use now and in the future. CDC incorporates partner feedback in our input through our engagement with national public health organizations (e.g., ASTHO, NACCHO, APHL, etc.). In an effort to educate stakeholders, CDC is also working to provide consolidated information to its programs and partners as well as through forums to the general public.

CDC Meaningful Use Website

CDC Meaningful Use Frequently Asked Questions

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