CMS Clarifies Electronic Transmission

One of the more confusing items about Meaningful Stage 1 is what constitutes a test of electronic record exchange.  The HIT Standards Committee did not specify transport standards, so there are no certification criteria to test the ability of an EHR to send data from place to place.

It was unclear what kinds of transport constitute a valid test of data exchange - Bluetooth between iPhones?  e-Fax?  USB Drives?

Now we know from a new CMS FAQ - any transport standard will do, but physical media will not.

Here's the language:

"To complete step 2, an eligible professional, eligible hospital, or critical access hospital may use any means of electronic transmission according to any transport standard(s) (SMTP, FTP, REST, SOAP, etc.) regardless of whether it was included by an EHR technology developer as part of the certified EHR technology in the eligible professional’s, eligible hospital’s, or critical access hospital’s possession.

Please note that the use of USB, CD-ROM, or other physical media or electronic fax would not meet the measure of this objective and has been addressed in another FAQ (see FAQ #10638)  If the test involves the transmission of actual patient information, all current privacy and security regulations must be met."

Now that we know, feel free to send me a secure email (Zixmail, Accellion, Direct, S/MIME, or TLS) and I can validate your test!