Get the facts regarding view, download and transmit 2014 requirements

Rebecca Mitchell Coelius, MD | January 31, 2014

As the Medical Officer for Innovation at the ONC and a proud member of the Blue Button team, I am working hard to understand the challenges and opportunities that lie ahead in the implementation of patient engagement functionality in EHRs, including new requirements that a certain percentage of patients view, download and transmit their health data in 2014.

We’ve been hearing about confusion around what to expect for view, download, and transmit (VDT) as part of the Meaningful Use requirements in 2014. We would like to address that confusion and offer a few tips for a successful year.

All providers and hospitals attesting to Meaningful Use in 2014 will need to implement the VDT capabilities for their patients. Those in Stage 1 will attest for access, those in Stage 2 will attest for use (see below). The term “online access” used in the VDT measure definitions refers to all three capabilities – view, download and transmit.

Attesting for Access:
Fifty percent of patients must have the ability to view their data, download it in both human and machine readable formats, and electronically transmit their data. Note the AND – patients must have access to all three functions during the provider’s reporting period. It is not accurate to say that any of these functions is optional.

The types of data that must be viewed, how quickly after an encounter with a provider or institution, and in what format it must be available to be downloaded and transmitted are explicitly defined in ONC’s and CMS’ rules. For example, the required machine-readable format for download and transmit purposes is the Consolidated CDA.

Attesting for Use:
Five percent of all patients must view, download, or transmit their data within the given reporting period. This may involve any combination of VDT, but does not mean that providers or institutions can turn the other functions off.

We are also hearing confusion surrounding whether the Direct Protocol is required for the transmit portion of VDT. Direct for patient transmit is required as part of ONC certification, so every certified EHR comes with this functionality. However, CMS attestation allows for providers to use other forms of transmit to meet their 50% “access” and 5% “use” requirements. The Blue Button team is interested to hear what other Transmit methods providers and hospitals are considering to achieve these requirements.

The Direct Protocol is currently the easiest way to meet the transmit requirement because Direct is built into certified EHRs, is the same transmit method that providers are using for Transition of Care requirements, and is currently being implemented by many patient- facing tools and applications, including those in the Blue Button Consumer Bundle. Judging from the enthusiastic turnout at our Blue Button Developer Forums, Challenges, and Codeathons this year, many more developers are eager to join the ecosystem as soon as they see providers and institutions ready to make the data available.

Finally, patients using VDT will choose where to transmit their own health information. Direct or any other transmit method should be implemented in a way that allows a patient to designate what Direct address or consumer application or tool will receive their information.

2014 will be an important year for Meaningful Use, Blue Button and the community of patients, providers, caregivers, and entrepreneurs building an ecosystem to support patient access to data. We are looking forward to hearing from you about your successes and concerns with meeting the view, download and transmit  requirements.