Notifications
Clear all
Topic starter
2nd part of HIE measure requires electronically transmit TOC to a receiving provider for more than 10 percent of transitions of care and referrals.
We are not able to find Direct Addresses for Referrals that we need to send electronically. Currently we are sending them using fax. I am not sure if FAX transmission would be eligible to count as numerator for 10%.
How to meet measure if providers that we sent referrals to do not have Direct Addresses?
Posted : April 25, 2016 7:16 am
We have been told that fax is not acceptable for electronic transmission however, CMS does accept transmission using an HIE so we hve turned to our HIE which we were already using fo rother things and they even wrote a report for us to collect the data. We have the same problem you have with most providers we refer to do not have a direct address and are not interested in getting one.
Posted : April 25, 2016 7:30 am
Faxing the referral will not count towards MU attestation for the TOC measure. I believe this will be one of the more difficult measures for many practices because you are dependent upon other providers having a secure (direct protocol) address. We are finding that many of the providers we send referrals to (or at least their staff) are clueless about the direct protocol and secure transmission of the TOC. That said, CMS does not require you to use the direct protocol for your TOCs in order to get credit, however they do require you to send the information electronically and securely. Faxing would not qualify as a secure medium but there are other options for those that don't have a direct protocol address. For example, our patient portal (ezAccess) has a physician facing component that allows us to transmit the TOC to the portal and then the physician can login to their portal account and access the TOC document directly. A notification is sent to their email telling them they have a secure document to review when we do this. This strategy would meet CMS' requirement, however we will need to keep track of those transmissions because the metric GE reports is based on the number of transmissions you made to direct protocol addresses. We are building our own MU reporting system for that reason. We can trust our metrics and defend them if the need ever arose.
Posted : April 25, 2016 7:47 am
There seems to be many threads about this topic - HIE Objective 5.
Here's a link to one of the other threads - this other thread touches on the topic of Faxing the Summary of Care record also:
https://centricityusers.com/forum/summary-of-care/#answer-179360#answer-179364#answer-182358
In many of these threads the statement about Faxing not being an acceptable method of transmission is suggested. I disagree with that premise. Faxing has been considered a HIPAA acceptable method of sharing patient data since its inception. I am not understanding why people are making the blanket assertion that Faxing is not secure? I can be wrong, and it would not be the first time, but I would need to see something from CMS stating that Faxing is not an acceptable method for transmitting the Summaries of Care record to those providers that do not utilize the Direct Protocol method before I would abandon that approach.
Can someone provide an official link to show where CMS states faxing does not qualify for this measure?
Until then my practice is planning to work under the premise that it is acceptable.
Having said the above, I will be the first to admit that the spirit of this measure by CMS was to get providers to share patient information electronically using standards that would allow data to easily be received into the providers EMR systems. Hence, the Direct Protocol sending CCDA documents. I believe CMS got too far down the road and then realized that a large percentage of the Provider population were not ready for this and they scaled back the requirement for this measure to simply be these things:
1) Summary of Care record must be created by CEHRT
2) The Summary of Care record must be transmitted Electronically at least 10% of the time
CMS also clarified in the Additional Information section that "The exchange must comply with the privacy and security protocols for ePHI under HIPAA"
From my understanding Faxing meets both the "Electronically transmitted and ePHI under HIPAA definitions.
Posted : April 27, 2016 10:18 am
UPDATE: I stand corrected. Faxing is NOT an acceptable method of transmitting the Summary of Care Record.
This morning a GE consultant was able to provide me with official CMS documentation stating that faxing is not an acceptable method for us to use on this measure.
Here is a quote from the CMS document:
"Note: Faxing in general is not acceptable since it is not in C-CDA format. It is only acceptable when a third party is used to transmit the summary of care record and they must convert the transmission to fax because that is the only way the receiving provider can accept the transmission. Additionally, the conversion to fax by the third party must not be a default approach. "
Here is the link to the actual CMS document .
Thanks,
Mike
Posted : May 6, 2016 4:36 am
