Reminder: EHR/PMP Integration Waiver Attestations Due

Nov 8, 2023
As a reminder, waiver attestations for Electronic Health Records (EHR)/PMP integration must be submitted annually, by December 1 of each year for the proximate year.

As a reminder, waiver attestations for Electronic Health Records (EHR)/PMP integration must be submitted annually, by December 1 of each year for the proximate year. For example, for calendar year 2024, providers should resubmit a waiver attestation by December 1, 2023.

EHR/PMP Integration Requirement

All health care facilities with ten or more prescribers, excluding critical access hospitals, must fully integrate their Electronic Health Records (EHR) systems with the state’s PMP or have obtained a waiver from the DOH. To be considered fully integrated, the EHR must be able to:

  • Send information to the PMP without provider intervention;
  • Allow current information from the PMP to be available to a provider within the workflow of their EHR; and,
  • It must make the information available in such a way where it is unlikely to interfere with, prevent, or discourage access or use of electronic health information.

How to Qualify for the EHR/PMP Integration Waiver

To qualify for a PMP/EHR integration waiver from the DOH, the organization must be experiencing:

  • Economic hardship of the following circumstances:
    • A bankruptcy in the previous year or a waiver submitted due to bankruptcy in the previous year;
    • Opening a new practice after January 1, 2020;
    • Operating a low-income clinic, which is defined as a clinic serving a minimum of thirty percent Medicaid patients; or,
    • Intent to discontinue operating in Washington prior to December 31, 2022.
  • Technological limitations not reasonably in control of the provider, where the method of integration of the EHR and PMP is in the approval process by the DOH but is not yet completed.
  • Other exceptional circumstances including:
    • Providing services as a free clinic;
    • The internet speed or bandwidth required for integration through a method approved by the DOH is not available;
    • The technology to connect the EHR of the provider through a method approved by the DOH does not exist;
    • Fewer than one hundred prescriptions for Schedule II-V drugs are generated in a calendar year; or,
    • Unforeseen circumstances that stress the provider or health care system in such a way that compliance is not possible. For example, natural disasters, widespread health care emergencies, unforeseeable barriers to e-prescribing, or unforeseen events that result in a statewide emergency.

EHR/PMP Waiver Attestation Form Information

The waiver will be granted upon submission of an attestation form. An attestation for a waiver due to technological limitations or economic hardship may be submitted three times, giving a provider up to three years to come into compliance with the integration requirement.

Most WSDA members qualify for the waiver under the exceptional circumstances category as they generate fewer than one hundred prescriptions of Schedule II – Schedule V drugs in a one-year period (both new and refill authorizations). The waiver will be granted upon submission of an attestation form, and there is no limit to the number of exceptional circumstance waivers that a provider may submit.

How to Fill out the EHR/PMP Waiver

When filling out the waiver, providers will be asked to select only one reason for submitting the waiver and should print the final page before selecting the “Finish” button.

To access the PMP/EHR integration waiver, please click here.