Public health agencies are the nation’s first line of defense against public health threats, whether that is a once-in-a-century pandemic, food products tainted with E. coli or Salmonella, or a surge in chronic diseases such as asthma or diabetes. They rely on high-quality, complete, and timely data from doctors, hospitals, labs, and health systems to detect and prevent these illnesses—but they don’t always get it.
Federal agencies can help. In particular, the Centers for Medicare & Medicaid Services (CMS)—through its Promoting Interoperability Program and Merit-Based Incentive Payment System—provides incentives for hospitals and health care providers, respectively, to report public health data using electronic tools. This data covers immunizations, individual cases of disease, lab results, and early warning signs from emergency rooms, known as syndromic surveillance.
However, there are gaps in the programs. For example, CMS asks hospitals and providers to report whether they are using electronic health records (EHRs) to send data for public health with a binary “yes” or “no.” Although this sounds straightforward, it does not give a complete sense of hospital performance in reporting public health data. For example, a hospital could attest that they are electronically sharing case reports but may only be sending reports for one condition. Additionally, the binary response does not allow CMS to assess whether hospitals sent the data to public health agencies quickly—ideally, within 24 hours of collecting it—so agencies can act promptly. In addition, although the data must be reported electronically, the information is not always standardized, which can disrupt processing and delay analysis.
Fortunately, CMS is exploring ways to improve the program and has requested responses to a series of questions in a recent proposed rule. In May, The Pew Charitable Trusts submitted comments informed by interviews with dozens of subject matter experts and discussion panels to find consensus around the best options.
Among its recommendations, Pew suggested that CMS:
The proposed public health reporting measures would build on ongoing federal efforts. For example, the Office of the National Coordinator for Health Information Technology (ONC) is using its own policy levers to assess the completeness of public health reporting. Recently, ONC finalized a rule to require vendors of certified electronic health record technology to measure the volume of administered immunizations that are successfully submitted electronically. In future rulemaking, ONC may require such vendors to report other metrics of public health data exchange, including for electronic lab reporting, and CMS could use incentives to encourage more robust public health reporting.
There is still work ahead and more discussion needed to finalize performance measures for reporting individual cases of illness and communitywide syndromic surveillance data. Even so, if CMS adopts Pew’s recommendations, it can strengthen the foundation for data sharing nationwide, making it easier for public health agencies to access and use higher-quality data to protect their communities.
Sheri Doyle works on The Pew Charitable Trusts’ public health data improvement project.