Electronic Health Record Certification: The 2015 Edition Requirement

An increasing percentage — approximately 80% — of physician practices have adopted EHRs to improve their clinical and administrative performance. The sharp increase in EHR use can be attributed, at least in part, to the availability of incentive payments to providers as part of the Centers for Medicare & Medicaid Services (CMS) Meaningful Use program and Quality Payment Program (QPP). Eligible clinicians (ECs) who participate in these programs are required to use certified EHR software. The challenge for practices has been the cost and disruption associated with upgrading their software to the higher certification levels.
 
To date, the Office of the National Coordinator for Health Information Technology (ONC) has released three certification levels, each with increasingly complex requirements. The first certification level, 2011 Edition, was the level required for the initial years of the Meaningful Use program. The second, 2014 Edition, was in place for the final years of the Meaningful Use program as well as the first two years of the QPP. ECs seeking to score points in Merit-based Incentive Payment System (MIPS) can select any consecutive 90-day period to report their Promoting Interoperability (PI) measures (worth a maximum of 25% of your total MIPS score). While the latest certification level, 2015 Edition, was optional for the 2018 QPP performance year, the recently released QPP final rule stipulates that eligible clinicians seeking to participate in an Advanced Alternative Payment Model or score points in the PI component of MIPS are required to have 2015 Edition Certified EHR Technology (CEHRT).
 
The Medical Group Management Association’s most recent MGMA Stat poll asked healthcare leaders, “Medicare MIPS requires ‘2015 CEHRT’ in 2019. Is your organization ready?” A total of 58% of respondents indicated that their organization was ready for the 2015 CEHRT, with 17% indicating that the transition to the new software was “in progress.” Another 17% responded that they were “unsure,” and 8% indicated that their organization was not upgrading to 2015 CEHRT. This poll was conducted on Nov. 13, 2018, with 752 applicable responses.

ONC maintains that, compared to the earlier certification editions, 2015 CEHRT facilitates greater interoperability for several clinical health information purposes, and enables health information exchange through new and enhanced certification criteria, standards and implementation specifications. Despite its potential efficiencies, the MGMA 2018 Regulatory Burden Survey  found that 77% of respondents felt very or extremely burdened by government EHR requirements. ONC has estimated that only two-thirds of practices have migrated to 2015 CEHRT, and the remaining third may face obstacles if they choose to upgrade.
 
Those who responded that their organization is “not upgrading” answered a follow-up question asking, “Why not upgrade?” More than half (55%) responded that they were not participating in the CMS Quality Payment Program, 23% stated that the transition was too expensive, 13% said it was too disruptive and 10% indicated that their vendor was not ready.
 
If your practice is considering an upgrade from 2014 CEHRT, consider the following action steps:

1. Decide if your ECs or group will seek to score points in the PI component of MIPS or participate in an Alternative Payment Model.
2. Discuss with your current EHR vendor whether it can upgrade your current software version to the 2015 Edition.
3. If your vendor is offering a 2015 Edition, determine when it will be able to upgrade your practice and the cost of the software, new hardware required and staff training.
4. If your vendor is not offering a 2015 Edition, decide if your practice wants to incur the cost and challenges required to replace your current EHR with a new vendor’s 2015 Edition.

*Note: The PI component of MIPS is worth a maximum of 25% of the total MIPS score. Even if the EC or group does not participate in the PI component of MIPS, the EC or group can avoid a penalty and potentially receive a bonus by maximizing scores in the other three categories: Quality, Improvement Activities and Cost.
 

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