The Jury Returns: MACRA – MIPS and 2019 CEHRT Requirements
Back in August I wrote a post entitled, “MIPS and EHR Certification: Most Asked Question”. The issue at hand was when did MIPS eligible providers need to be using 2015 Edition Certified Electronic Health Record Technology (CEHRT). Some voices had expressed hope that the option of using either 2014 or 2015 CEHRT, as is the case in 2018, would be continued through 2019. The November 1st release of 2019 Quality Payment Program final rule has finally put that issue to rest. Here is the relevant text embedded in that 2000+ page document.
Comment: A few commenters requested clarification on whether or not practices will be required to use 2015 Edition CEHRT for the entire performance year for quality and the latest version of eCQM to earn the end-to-end bonus.
Response: The definition of CEHRT for 2019 and subsequent years is EHR technology (which could include multiple technologies) certified under the ONC Health IT Certification Program that meets the 2015 Edition Base EHR definition (as defined at 45 CFR 170.102), and has been certified to the 2015 Edition health IT certification criteria. In the CY 2017 Quality Payment Program final rule (81 FR 77297), we finalized that the CEHRT bonus would be available to MIPS eligible clinicians who report via qualified registries, QCDRs, EHRs, or the CMS Web Interface for the Quality Payment Program, in a manner that meets the end-to-end reporting requirements. Thus, in order for practices to earn the end-to-end bonus for reporting eCQMs for the 2019 performance period, they will need to be reporting using the latest version of the eCQM and will need to use CEHRT that has been certified to the 2015 Edition.
As we finalized previously (82 FR 53671-53672) beginning with the performance period in 2019, MIPS eligible clinicians must use EHR technology certified to the 2015 Edition certification criteria as specified at §414.1305.
So that should put the matter to rest. 2015 Edition CEHRT is required in 2019 for the appropriate MACRA & MIPS reporting period. Some reporting periods are 90 days which means October 2019 is the deadline to be using 2015 CEHRT. However, since the reporting period for Quality is the full year, if you are looking to earn that “end-to-end bonus for reporting eCQMs”, the reporting will need to be done using 2015 Edition CEHRT.
Finally, the death of the CEHRT program has been greatly exaggerated. Some believed it would disappear after the Meaningful Use program only to see it become a requirement of MACRA/MIPS. There are a number of current programs that reference CEHRT. Certified technology has become a foundational element of electronic health records and is not going away.