Guidance Issued for MU Data Exchange

The Centers for Medicare and Medicaid Services has issued guidance designed to aid eligible professionals in complying with three objectives in the Stage 2 meaningful use requirements. The four-page tipsheet covers the specific data elements that are needed to complete the clinical summary, patient electronic access and summary of care objectives—all of which include what type of information should be shared with another party.

While some of the data elements are common between the requirements, others are individual to each objective, according to the document.

For example, for the clinical summary requirement, CMS requires eligible professionals to include specific information for 20 different data fields, including vital signs and clinical instructions given for a specific visit. It also requires that they must offer the information to the patient either online or on paper within one business day. 

For the patient electronic access objective, the eligible provider must offer patients the ability to view online, download and transmit their health information within four business days. Such information includes 12 specific data fields, including problem list, medication list, allergy list and care plan, all of which must contain either problems, medications, allergies or a notation that the patient has none.

For both of these requirements, if the provider has not yet entered a specific data element into their EHR at the time the clinical summary or electronic access is offered to the patient, that field can be left blank and the provider can still meet the requirement. Further, the provider can withhold any information to the patient that they determine could cause possible harm.

The purpose of the summary of care objective is to ensure that a new provider is offered the most up-to-date information from a previous provider. It includes data for 16 different fields, as well as a requirement that the eligible provider must verify that some kind of information was entered into the EHR for the problem list, medication list, medication allergy list and care plan before submitting it to the new provider. Providers will not be able to meet the objectives of the requirement if these fields are left blank. However, like the clinical summary and the patient access objectives, the summary of care enables eligible professionals to offer only the information that is available in their EHR at the time they submit the summary of care.