Electronic Case Reporting in 2025

January 10, 2025

Electronic Case Reporting (eCR) has been required under the MIPS Promoting Interoperability (PI) category since the beginning of performance year 2022. As we head into the fourth year of required eCR, let’s review which states are ready to receive eCR and what to do if your state has not yet declared readiness.

What Does This Mean for Your Practice?

Nearly all states have declared readiness, so your practice should be prepared to report on this measure unless you qualify for an exclusion. In this blog, we’ll outline the latest updates and let you know what to do if your state is not ready yet.

What Is eCR?

eCR allows automated, real-time exchange of relevant clinical data between EHRs and public health agencies (PHAs), streamlining the case reporting process. Before the onset of the COVID-19 pandemic, PHAs often didn’t have eCR functionality enabled, so EHRs had little incentive to develop the functionality.

However, once the pandemic highlighted the issues with the U.S. public health infrastructure, the Centers for Medicare and Medicaid Services (CMS) decided to require eCR beginning with MIPS performance year 2022. This policy has the goal of facilitating less burdensome, more complete, and more accurate public health reporting.

How Does eCR Work?

eCR consists of five steps:

The patient is diagnosed with a reportable condition (e.g., COVID-19).
Their provider enters this information into their EHR.
The EHR automatically triggers a case report, which is validated and then sent to the appropriate PHAs.
The PHA receives the report in real-time and notifies the provider regarding the reportability of the case.
The state health department reaches out to the patient for contact tracing or other public health actions.

For these steps to occur, the state health department must be prepared to receive the automatically triggered case reports, but not every state has declared readiness to do so.

Which States Are Ready to Receive eCR?

As of January 2025, Texas and Mississippi are the only states that have not yet declared readiness.

What If My State Is Ready to Receive eCR?

If your state is ready to receive eCR, it's important to communicate directly with the relevant public health authority to start the process and ensure you can participate. The eCR measure requires active engagement to earn full points for your PI score.

Active Engagement 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.

Note that, starting with performance year 2024, MIPS eligible clinicians may only remain in Option 1 for one performance period. If you were in Option 1 in 2024, you must transition to Option 2 in 2025.

What If My State Isn’t Ready to Receive eCR?

CMS allows for three exclusions to this 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.

If your state is not yet ready to receive eCR, you should prepare to claim the third exclusion for this measure.

Next Steps

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Written By: Sarrah Hakim, MHSA