In comments submitted to the Centers for Medicare and Medicaid Services, health IT industry groups praised the agency for adding in more flexibility for EHR certification requirements into the 2018 Quality Payment Program (QPP). But those same groups also envision several different paths regarding certification in 2019 and beyond.
Organizations like HIMSS, the American Health Information Management Association (AHIMA), the College of Healthcare Information Executives (CHIME) and the American Medical Informatics Association (AMIA) were supportive of CMS’s recent proposal to allow physician practices to use EHR systems that meet either 2014 or 2015 certification requirements to participate in QPP in 2018, the physician payment structure finalized under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). In the lead-up to the proposed rule, many of those same organizations had urged CMS to extend the Jan. 1, 2018 deadline to meet 2015 Certified Electronic Health Record Technology (CEHRT) requirements, arguing that most vendors had not made the necessary upgrades.
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“As recently as the start of August we have members reporting that they are not sure when they expect to receive their 2015 Edition CEHRT,” CHIME CEO Russell Branzell wrote (PDF) in comments submitted to CMS, adding that at least one member worried their vendor “may never be certified.”
The organizations generally agree that simplicity and flexibility are important to QPP. But groups like HIMSS and the Personal Connected Health Alliance want CMS to set a January 2019 start date for all practices meet 2015 EHR certification requirements, noting that the 2015 Edition’s emphasis on interoperability and APIs that are a “significant part of our commitment to health IT supporting healthcare transformation.”
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AMIA also pushed CMS to set a definitive 2019 deadline, while the American Hospital Association offered a tepid call for CMS to “reconsider inclusion” of 2015 certification in 2019.
“This will signal to industry that they must continue investment in CEHRT and prepare clinicians for a nationwide upgrade to 2015 Edition products,” wrote Douglas Fridsma, M.D., AMIA’s president and CEO, along with Board Chair Thomas Payne, M.D.
Others, like Health IT Now, see the delay as an opportunity to rethink the 2015 requirements altogether. Executive Director Joel White wrote that new legislation in MACRA and the 21st Century Cures Act along with technological advancements “necessitates a review of requirements that are now over two years old.”
Although CHIME didn’t comment on whether to set a 2019 deadline for the 2015 Edition, the group did advocate for rewarding practices that aren’t addressed in the requirements, like using artificial intelligence, improving cybersecurity and incorporating virtual machines or robotics.
“As far as we can tell, there is nothing in the statute that precludes CMS from reimbursing under the [incentive activities] category for technology-facilitated solutions that are not part of a certified EHR,” Branzell wrote.