Due to expected requirements of the Quality Payment Program (QPP) in 2018, many vendors of Electronic Health Records (EHRs) have been scrambling to achieve the Office of the National Coordinator (ONC) 2015 Certification Edition. However, the Centers for Medicare and Medicaid Services (CMS) has just released the proposed rule for the 2018 performance year causing clinicians and vendors alike to breathe an enormous sigh of relief.
In the proposed rule for the 2018 performance year, CMS states that they will continue to allow eligible clinicians to use EHRs that are certified for the 2014 edition, although they will offer bonus points for using only a 2015 Edition Certified EHR Technology (CEHRT). Why is this a big deal? If you’ve ever had to upgrade your entire practice management and EHR software, you already understand. It can be quite an overwhelming experience. This proposal also allows for vendors to take their time and upgrade their software to the new standards without wreaking havoc on the lives of their clients and, of course, on their own development team. By giving them more time, the upgrade can be done thoroughly and thoughtfully so that users and developers alike, experience fewer glitches in the system and enjoy a much smoother upgrade overall.
Additionally, the 2018 performance year will bring with it exclusions for e-prescribing and certain health information exchange measures. Eligible clinicians will also have more opportunities to earn bonus points. Small practices once again get a nod as CMS is proposing to add hardship exceptions to reweight the Advancing Care Information category to 0 and reallocate those points to the Quality Category. And the same will happen automatically for clinicians who are based in an ambulatory surgical center. Anyone who feels they qualify for an exception to the Advancing Care Information Category will now have until December 31st of the performance year to submit their application. CMS is also proposing to make this change retroactive to the 2017 performance period.
Finally, CMS is adding in additional bonus points with regards to registry reporting and taking away the requirement of the immunization registry which makes sense for a lot of practices. And if, by chance, your EHR recently lost its certification, CMS is going to offer these clinicians a “decertification exception” that is proposed to be retroactive for the 2017 performance year. If you’re not positive about the certification status of your current EHR, you can easily find the information by typing in your vendor’s name at https://chpl.healthit.gov/#/search. It will show you whether they are actively certified and for what edition. Make sure you ask your vendor if the company is planning on becoming certified for the ONC 2015 Edition as this will become a requirement for the 2019 performance period.