Frequently Asked Questions

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[EHR Incentive Programs] To meet the Stage 1 public health meaningful use objectives for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs, does a provider have to send information directly from their certified EHR technology to the appropriate receiving entity or can they use an intermediary such as a health information exchange (HIE) or another third-party software vendor?

CMS recognizes that there are a variety of methods in which the exchange of public health information could take place. In order to promote the submission of public health information to appropriate entities, we do not seek to limit or define the receiving capacities of said entities. In order to satisfy the public health meaningful use objectives, a provider must conduct one test of information exchange according to the following criteria:
The information required for the public health meaningful use objective must originate from the provider's certified EHR technology; and The information sent from the provider's certified EHR technology must be formatted according to the standards and implementation specifications associated with the public health meaningful use objective.  If an intermediary performs a capability specified in an adopted certification criterion and a provider intends to use the capability the intermediary provides to satisfy a correlated meaningful use requirement (submission to public health according to adopted standards), the capability provided by the intermediary would need to be certified as an EHR Module (see ONC FAQ 18 for more information).

For more information about the Medicare and Medicaid EHR Incentive Program, please visit

Keywords: FAQ10764


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