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Implementing California AB 2325

Implementing California AB 2325

California Assembly Bill 2325 (AB 2325) was signed by Governor Jerry Brown on September 14, 2016, requiring pathologists who diagnose cancer to provide their cancer pathology reports to CCR electronically before January 1, 2019. A pathologist or pathology lab will be able to satisfy reporting compliance by adhering to the reporting requirements and standardized format regardless of the technical platform used to capture, store, and submit data. Download the CCR Electronic Pathology Reporting Standards Implementation Guide to learn more about how to implement AB 2325.

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Pathologists and pathology software providers will need to review this Implementation Guide and register with CCR to meet California reporting requirements. Pathologists may report through the pathology portal.

Answers to Your Most Frequent AB 2325 Questions

How has AB 2325 changed cancer reporting in California?

AB 2325 includes 5 new articles within Section 103885 of the California Health and Safety Code:

  • (3) (A) On or after January 1, 2019, a pathologist diagnosing cancer shall report cancer diagnoses to the department utilizing the College of American Pathologists cancer protocols or any other standardized format approved by department.
  • (B)  Reporting shall be by electronic means, including, but not limited to, either directly from an electronic medical record or using a designated Internet Web portal that the department shall provide for pathologists’ use. If a pathologist fails to report electronically and with an approved format, the department’s authorized representative may access the information from the pathologist in an appropriate alternative format. In these cases, the pathologist shall reimburse the department or the authorized representative for its cost to access and report the information.
  • (C)  A pathologist shall not be responsible for acquiring missing or inaccessible patient demographic information not provided to him or her beyond the content of the required cancer-specific data elements.
  • (D)  For purposes of reports submitted pursuant to this paragraph, the department shall prescribe the data required to be included in the report, work collaboratively with stakeholders to designate a standardized electronic format for submission, and designate an Internet Web portal for electronic submission.
  • (E)  This paragraph shall not be interpreted to require a pathologist to submit the same pathology report to the department, regardless of format, more than once. If a pathology report is submitted by a pathologist electronically, pursuant to this paragraph, the same pathology report is not required to be submitted to the department by any other means.

How can pathologists obtain a copy of the CCR Electronic Pathology Reporting Standards Implementation Guide?

Where can pathologists register to report?

Pathologists can register to report on the CCR website here.

How do I access the reporting portal?

You can register to report on the CCR website here.

How do I use the HL7 self-testing portal to validate my data submission format?

Use our Health Level 7 (HL7) self-testing portal to validate data quality and compliance here.

Will use of the College of American (CAP) Electronic Cancer Checklists (eCC) be required for pathologists to meet the California reporting mandate?

No, CAP eCC is not a requirement of the state to meet the California pathology reporting requirement. However, use of software which supports discrete data capture, such as CAP eCC, is highly encouraged in order for CCR to efficiently process cancer incidence data and achieve future uses of data envisioned by CCR.

If my pathology department or lab already reports to CCR, will the requirements for reporting change?

Pathology laboratories currently submitting data to CCR electronically utilizing National Cancer Institute (NCI) or Centers for Disease Control and Prevention (CDC) supported methods for electronic reporting (AIM, PHIN MS), or Office of the National Coordinator (ONC) HL7 standard for Structured Data Capture (SDC) using CAP eCC, meet the transmission methods for submitting data. However, all pathology departments and laboratories should reference the CCR Electronic Pathology Reporting Standards Implementation Guide and review the reporting requirements to ensure the required data are being transmitted.

If my pathology department or lab already reports to CCR, should reporting be discontinued until the new reporting requirements are defined and the Implementation Guide is released?

No, CCR will continue to accept pathology reports in their current form from current sources. Pathology departments and labs should plan to review the Implementation Guide, implement any new changes per defined reporting requirements, and work with CCR to meet the legislative reporting mandate for pathology reporting before the January 1, 2019 deadline.

If my pathology department or lab does not currently report to CCR, when is the new legislation effective?

The legislation for pathologists to report becomes effective as of January 1, 2019. Pathologists, pathology departments, pathology labs and pathology software vendors should plan accordingly to comply with California reporting requirements and begin to submit data to CCR reporting before the January 1, 2019 deadline.

When will the Direct Data Entry Web Portal be available?

The Direct Data Entry Web Portal will be available by July 31, 2018 in alignment with the mandate for pathologists to comply with the electronic reporting legislation.

Will CCR be working with San Diego Health Connect (Health Information Exchange) to establish electronic connectivity?

All facilities should proceed with the registration process at the current time. When selecting the “Data Submission Method” at the bottom of the registration page, select “Electronic Interface” and “SOAP Web Service.” Indicate in the Vendor Information section that your preference would be to leverage a data exchange profile within SDHC.

I have a customer asking if we can develop the LIS side of the interface to support sending of multiple CCR facility IDs. Are the Registry IDs the same as the lab’s unique Clinical Laboratory Improvement Amendments (CLIA) identifier I see referenced in the Standards Draft?

Yes, CCR uses the CLIAs to identify the sending facilities. CCR does map to an internal registry ID, but all lab reports enter our system and are validated by the CLIA.

Can we upload a list of pathologists to the registration portal or do they need to be added manually?

There currently is not a way to upload a list of names. It is a one-time process upon registration. CCR will not be asking facilities to update represented pathologists with changes at this point in time.

If my organization has multiple locations, do I have to register all of the facilities?

Yes, all of the facilities must be registered.

What if I have multiple pathologists, do we have to register all of the pathologists?

Yes, all of the represented pathologists will need to be registered.

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To learn more about how to meet the requirements of AB 2325, download the CCR Electronic Pathology Reporting Standards Implementation Guide.

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