The final rule for 2019 Quality Payment Program was released earlier this month. Although there are many important updates in the rule, there is one item in particular that seems to be causing a lot of confusion. We have received many variations of this core question – “Is 2015 Edition Certified EHR required for 2019? If so, by what date?”. Just like many other business questions, the answer is “it depends”. In this blog, I am going to discuss some of the factors that it depends on.
First of all, it is important to understand that contrary to common belief, Certified Health IT (commonly known as Certified EHR) applies to more than just the MIPS program. A list of all programs that require Certified EHR in some way or the other is available here. We can’t cover all these programs in one blog. So in this one, we will focus on MIPS. Contact us if you are participating in any of the other programs and would like to discuss the requirements.
2015 Edition Certified EHR Technology and MIPS 2019
You need to have a 2015 Edition Certified EHR for 2019 MIPS performance year for any requirements related to EHR. 2014 Edition Certified EHR is not valid any more for MIPS. Period. However, what exactly do you need and when you need it may differ based on your specific requirements. Here is how 2015 Certified EHR applies to Promoting Interoperability and Quality performance categories of MIPS:
PROMOTING INTEROPERABILITY CATEGORY
To earn points in the Promoting Interoperability (PI) category, you need to use a 2015 Edition Certified EHR for the entire duration of the performance period that a provider is reporting on (a minimum of any continuous 90 days). The provider needs to have access to features that support their specific MIPS requirements during the entire performance period. Note that the EHR does NOT need to be certified for the full 90 days. It only needs to be certified on the last day of the performance period. So, as long as a provider has access to the applicable PI features by October 3rd, 2019 and the EHR completes its certification before end of year, the provider can still earn the full PI points. I don’t recommend pushing this to last minute but that is the rule.
It gets really interesting for the quality category. As we have discussed in multiple blogs before, the Quality score really depends on the measures that you submit AND the “submission method” that you use to submit those measures. The 2019 final rule replaces the concept of “submission method” with a new concept of “collection types”. The collection types deserve a blog of their own. Here is a short summary: Providers can only report on measures under one submission method category till this year. Starting in 2019, providers may mix and match those measures to maximize the Quality category score. This is a big deal. Here is how 2015 EHR fits into all of this:
Using Qualified Registry (MIPS-CQMs) ONLY: If you will be using MIPS-CQMs (previously called registry measures) for submission in 2019, the 2015 Edition EHR does not apply to you. I have heard a lot of comments that a 2015 Edition Certified EHR is required to earn end-to-end reporting bonus for these registry measures in 2019. That is not correct. The end-to-end reporting bonus is based on the registry’s method of data collection and is not based on the 2015 Edition EHR certification in any way.
Using EHR (eCQMs) ONLY: If you use EHR measures commonly referred to as eCQMs, you do need to make sure that you have a 2015 Edition Certified EHR. This is where it gets really complicated. Quality category requires full year reporting in 2019. Based on the 2015 EHR requirements, you should be able to report on the eCQMs even if the EHR is certified AFTER 1/1/2019. However, you definitely need to have the 2015 Edition certified EHR early in the year to report on those measures. There is some confusion around how soon in the year should that be. We are hoping to get more clarification from CMS in coming days.
Using both eCQM and MIPS-CQMs: If you would really like to leverage the changes in 2019 rule to get the best Quality score, you need to be able to analyze the best measures across eCQMs, MIPS-CQMs, and other MIPS measures. As discussed in (2) above, you should be able to do that as long as you have a 2015 certified EHR during 2019.
BEYOND CMS INCENTIVE PROGRAMS
It is important to mention that Certified EHR has value beyond CMS programs. ONC recently announced a EHR Reporting Program. As part of the program, ONC will provide publicly available comparative information on Certified Health IT. The program will reflect input from the developers and voluntary input from end users of Certified Health IT to design reporting criteria that will inform the purchasing and implementation decisions of Certified Health IT users.
MyMipsScore is a qualified registry for all the MIPS (previously known as registry) measures. In addition MyMipsScore has a 2015 Edition Certified EHR add-on component for 53 eCQMs. We are really excited with the changes in the final rule as this allows our users to collect, analyze, and report on any quality measure with any collection type. Our soon to be released 2019 MyMipsScore edition would allow users to compare eCQMs and MIPS-CQMs (registry measures) from a single screen similar to our current MIPS Score Simulator. Contact us if you are interested in learning more about the 2019 edition and getting early access to it in December.
If you are an EHR vendor currently working on 2015 EHR Certification, contact us to learn how you may be able to integrate your EHR with MyMipsScore and blend with our 2015 certification. This includes our current quality modules as well as some new modules that we are in the process of certifying. For a limited time, we are waiving off our integration fees for EHR vendors for the 2015 Edition certified module. That’s a deal you don’t want to miss.