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CMS is mandating new electronic case reporting requirements. Here's how providers can prepare.

By Ashley AntonelliJoseph Leonard

December 1, 2021

The Covid-19 pandemic spotlighted many shortfalls in the U.S. health system, and America's aging and inadequate public health infrastructure quickly stood out as a problematic sore thumb. As the coronavirus spread and Covid-19 cases skyrocketed, it became painfully clear that the United States lacked the ability to facilitate the rapid exchange of actionable patient data between health care providers and public health agencies working to combat the virus' spread.

This gap was particularly evident when it came to case reporting, a process in which providers are required by law to report certain diseases and conditions to public health agencies (PHAs). Case reporting data serves as a vital tool for PHAs. They rely on these reports for case management, disease monitoring, investigation, and a host of other services.

Given how quickly and seamlessly most people and businesses transmit data today, you'd likely imagine case reporting is relatively easy for providers—probably done with a few clicks of a mouse or taps on a screen. But in reality, this process is typically done manually, often still relying on outdated, slow technology such as fax machines. And the onerous process regularly results in PHAs receiving inaccurate or incomplete data, which necessitates follow-up conversations that further pull providers into administrative functions and away from their patients.

In the years leading up to the pandemic, there was little push toward electronic case reporting (eCR), which is the automated, real-time exchange of relevant clinical data between EHRs and PHAs for case investigation and follow-up. Although eCR drastically streamlines the case reporting process, most states haven't yet required providers to implement eCR functionality and many PHAs haven't been able to receive case reports in an electronic format. As a result, EHR vendors have had minimal incentive to provide this functionality.

So when the pandemic struck, the U.S. health system largely was caught unprepared to transmit and share vital data among the boots-on-the-ground entities that could curb the coronavirus' spread. Many providers—whose resources already were strained from managing an influx of Covid-19 patients—had to manually track and report Covid-19 cases and comply with reporting requirements that varied between localities, states, and the federal government. And because that process is burdensome and complex, PHAs were slow to get the timely, actionable data they needed to adequately track the coronavirus' spread and deploy needed resources to Covid-19 hot spots.

A new requirement for eCR—and help for providers

CMS recognized these shortfalls and took action to remedy them. Under federal regulations set to take effect in 2022, CMS mandates that hospitals and clinicians must implement and use eCR as part of their Promoting Interoperability program requirements. That means if hospitals and clinicians don't participate in eCR in 2022, they could face significant financial penalties.

But the new requirement comes with a golden opportunity for health systems and providers to implement eCR functionality and take advantage of the benefits eCR can offer—without additional burden or disruption to their clinical workflows. Efforts made by the federal government to mitigate the data sharing challenges providers and PHAs faced throughout the pandemic culminated in a new initiative called eCR Now, which offers a certified technology solution to electronic case reporting.

eCR Now is a joint project of the CDC, the Association of Public Health Laboratories, and the Council of State and Territorial Epidemiologists that offers an opportunity for providers to streamline their case reporting. The initiative allows providers to rapidly adopt and implement electronic case reporting by:

  • Using existing capabilities within their EHR; or
  • By using the eCR Now FHIR App to add eCR functionality to their EHR.

eCR Now allows providers to onboard in as few as three days with many EHR systems. Further, eCR Now has established a trust network with eHealth Exchange and Carequality that allows eCR to be implemented without additional legal agreements. The eCR Now FHIR App also is freely available for EHRs to implement.

Leaders need to act now to capitalize on eCR benefits and avoid regulatory penalties

Health system and clinician leaders must act now to realize the benefits that electronic case reporting—particularly with the assistance available from eCR Now—can provide, including:

  • Minimizing disruption to clinical workflow by eliminating the need for providers to manually submit case reports and conduct secondary reporting and investigation;
  • Enabling PHAs to see real-time clinical case data that can be used for case management, disease monitoring, and investigation; reduce need for follow-up investigation; and improve communication and collaboration with health care providers that can lead to an increasingly tighter bond between these stakeholders; and
  • Meeting new federal requirements for hospitals and clinicians to enable and use eCR functionality with implementation and regulatory support from eCR Now—which ultimately can help hospitals and clinicians avoid significant financial penalties from CMS.

As providers look to take implement eCR functionality, there are three steps leaders can take to ensure readiness:

  1. Stay informed of your EHR vendor's projected timeline for implementing certified eCR functionality and consider other options—such as working with eCR Now or potentially claiming an available exclusion from the eCR Promoting Interoperability program requirements—if you expect not to have certified eCR functionality in 2022;
  2. Contact the eCR Now team at to begin the process of integrating the electronic case reporting infrastructure that eCR Now provides and assemble your implementation team; and
  3. Once eCR functionality is in place, contact your state PHA to navigate their onboarding process to begin sending electronic case reports.

For more information on the new Electronic Case Reporting Measure requirements under the Promoting Interoperability programs for hospitals and clinicians for 2022, and for more information on eCR Now, check out Advisory Board's recent webinar: What you need to know about the hospital Promoting Interoperability program changes for 2022.

Advisory Board's Promoting Interoperability Program Toolkit provides additional detail on Promoting Interoperability program requirements for hospitals, while our MIPS toolkit provides additional detail on Promoting Interoperability requirements for clinicians who participate in the Quality Payment Program.

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