Electronic Case Reporting: Clarification on Active Engagement Option 2 Deadline
The Centers for Medicare and Medicaid Services (CMS) has released additional guidance on how to fulfill the electronic case reporting (eCR) measure, which is required for the Promoting Interoperability (PI) category under MIPS.
For an overview of the eCR measure in 2025 and what it means for your practice, take a look at our previous blog.
What Are the Active Engagement Options?
Clinicians must demonstrate “active engagement” with a Public Health Agency (PHA), in this case an eCR registry, through one of the following two options:
- Option 1 – Pre-Production and Validation:You are in the process of registering with the PHA and/or testing electronic submission of data.
- Registration must be completed within 60 days after the start of the performance period, while awaiting an invitation from the PHA to begin testing and validation.
- The MIPS eligible clinician must respond to requests from the PHA within 30 days; failure to respond twice within a performance period would result in the MIPS eligible clinician not meeting the measure.
- Option 2 – Validated Data Production:You are fully integrated and are electronically submitting data to the PHA.
When Do I Need to Be in Option 2?
Beginning with performance year 2024, MIPS eligible clinicians may only remain in Option 1 for one performance period. This means that, if you were in Option 1 in 2024, you must be in Option 2 in 2025.
CMS has clarified that you have until the last day of your 180-day PI performance period to transition to Option 2. For example, if you were Option 1 in 2024 and your PI performance period in 2025 started on 07/05/2025, you would have until 12/31/2025 to advance to Option 2.
What If I’m Having Difficulty Getting to Option 2?
CMS allows for three exclusions to the eCR measure:
- The clinician does not treat or diagnose any reportable diseases for which data is collected by their jurisdiction’s reportable disease system during the performance period.
- The clinician operates in a jurisdiction where no PHA can receive eCR data in the standards required to meet the CEHRT definition at the start of the performance period.
- The clinician operates in a jurisdiction where no PHA has declared readiness to receive eCR data as of six months prior to the start of the performance period.
New CMS clarification on eCR exclusions: CMS has clarified that the second exclusion is applicable if you have registered with the PHA to advance to Option 2 and the PHA will not work with your EHR, or if the PHA hasn’t moved you forward to Option 2 in time for the end of the PI performance period (i.e., you are still waiting on the PHA).
Next Steps
- Share this information with your colleagues.
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- If you are an Anatomy IT client, contact your MIPS Expert if you have any questions.
If you are not an Anatomy IT client, contact us to learn more about our MIPS Success Plan and to reap the rewards of our combined decades of experience.
If you have any questions on this, let us know!
Written By: Sarrah Hakim, MHSA
About the Author: Sarrah is a Manager of Health Policy at Anatomy IT.
