Home > EHR, meaningful use, Medicare > Additional Information on MU Stage 1 and 2 “View/Download/ Transmit” (Patient Portal) Objective

Additional Information on MU Stage 1 and 2 “View/Download/ Transmit” (Patient Portal) Objective

It has been a busy couple of weeks in the Medicare/Medicaid EHR Incentive Program. While everyone’s focus was on the Centers for Medicare and Medicaid Services’ (CMS) final rule to allow a certain subset of participants to meaningfully use (MU) EHR technology with outdated certification status, as well as on the Office of the National Coordinator for HIT’s (ONC) “Release 2” of the 2014 Edition EHR certification criteria, CMS distributed some clarifications regarding the Stage 1 and Stage 2 MU objective for “view/download/transmit (V/D/T),” also known as the “patient portal” or “PHR” objective. Most of this information was included in the September 2012 “Stage 2” final rule and the “Patient Electronic Access Tipsheet,” but it is worth repeating…

First, patients who choose not to access their health information (“opt out”) can be counted in the numerator of the Stage 1 and 2 “provide patients with ability” measure of the V/D/T objective if they are given all information needed to change their minds and access (or “opt in”) without having to reconnect with the provider. CMS’ example of doing this is when a patient is given a user ID and password combined with instructions about how to access the portal/PHR/patient website and how to create an account. Patients who choose not to access/opt out are required to be included in the denominator regardless.

Second, for the Stage 2-only second measure of “patients viewed, downloaded, or transmitted to a 3rd party” of that objective, patients who access their health information via an online personal health record (PHR) during the reporting period can be counted in the numerator for all eligible providers who contributed information to that PHR. The patient does not have to V/D/T the specific information contributed by an individual provider for it to count.

Third—and this is more obvious—everyone in a group practice is able to share credit for the Stage 2-only second measure of “patients actually viewed, downloaded, or transmitted to a 3rd party” if they each saw the patient during the same reporting period and are using the same certified EHR technology.

From a radiology perspective, I am constantly asked if imaging results need to be included in patient portal/PHR for the V/D/T objective. The answer is simply no—doing so would be beyond the minimum MU compliance requirements. The data elements that must be offered for V/D/T when updated are the “Common MU Data Set” in addition to the provider’s name and office contact information. Therefore, if all radiologists did was provide patients with access to key images and/or reports via the portal and did not include the Common MU Data Set, etc., this would actually not be in MU compliance. However, providing radiology information to the patient in addition to the basic data types required for MU may be desirable or even necessary for non-MU reasons, and it could give the patient a motivation to V/D/T their own health information on the radiologist’s portal for credit towards the second measure of the Stage 2 MU V/D/T objective.

Categories: EHR, meaningful use, Medicare
  1. Tim Ninke
    November 3, 2014 at 2:06 pm

    The Tipsheet seems to be incomplete. For example, there are only Questions and no Answers.

    • mpetersacr
      November 3, 2014 at 3:04 pm

      The answers in CMS’ tipsheet are provided below each corresponding question.

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