CMS Releases Guidance on Stage 2 Summary of Care Measure

CMS release guidance yesterday that it has discontinued the NIST EHR-Randomizer effective today, July 1. Hospitals and providers were previously required to conduct a test with the NIST EHR-Randomizer as part of their demonstration of the Stage 2 Summary of Care Record if they were unable to exchange a summary of care record with another provider with different CEHRT. CMS now permits hospitals and providers to retain documentation if they were not able to interact with a provider with different CEHRT in common practice, and attest "Yes" to this measure nonetheless.  

The text of the FAQ is available below.  For additional guidance on the Stage 2 Summary of Care Record measure, visit the CMS FAQ page.   

Question: When reporting on the Summary of Care objective in the Medicare and Medicaid Electronic Health Records (EHR) Incentive Program, how can eligible professionals and eligible hospitals meet measure 3 if they are unable to complete a test with the CMS designated test EHR (Randomizer)?

Answer: CMS is aware of difficulties related to systems issues that eligible professionals, eligible hospitals, and critical access hospitals (CAHs) are having in use of the CMS Designated Test EHRs (NIST EHR-Randomizer Application) to meet measure 3 of the Stage 2 Summary of Care objective, therefore, we will be discontinuing this option effective July 1, 2015.

Providers may still meet the Stage 2 Summary of Care objective measure #3 by using one of the following actions:

  1. Exchange a summary of care with a provider or third party who has a different CEHRT as the sending provider as part of the 10% threshold for measure #2 (allowing the provider to meet the criteria for measure #3 without the CMS Designated Test EHR). This exchange may be conducted outside of the EHR reporting period timeframe, but must take place no earlier than the start of the year and no later than the end of the EHR reporting year or the attestation date, whichever occurs first.
  2. If providers do not exchange summary of care documents with recipients using a different CEHRT in common practice, they may retain documentation on their circumstances and attest “Yes” to meeting measure #3 if they have and are using a certified EHR which meets the standards required to send a CCDA (§ 170.202).