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CEHRT and its MACRA and QPP Implications for Eligible Clinicians

Published on 10/18/2018
Certified EHR Technology (CEHRT) is a term that has been around as long as the Meaningful Use (MU) program, which is now the Promoting Interoperability (PI) program. The concept predated PI (notably for EHR safe harbors to the Stark and Anti-Kickback laws) but CEHRT and PI went hand in hand for many years.  

However, the concept of CEHRT is, and has been, expanding because of the Quality Payment Program (QPP) requirements of the Medicare and CHIP Reauthorization Act (MACRA) for the Merit-based Incentive Payment System (MIPS) and Alternative Payment Model (APM) requirements. Many more programs are requiring CEHRT, and we expect to see that number continue to increase. For health care providers and clinicians, this means ensuring compliance and use of a CEHRT system even as they move away from MU and PI and into APMs.  

What is CEHRT and what is changing?  

CEHRT is a health IT product that has successfully passed testing on specific standards and criteria selected by the Centers for Medicare and Medicaid Services (CMS) for use in specific programs. CEHRT can be achieved through use of a single system or a combination of modules that can be used together. These standards and certification criteria are outlined and maintained by the Office of the National Coordinator (ONC). There are varying editions of CEHRT as well. At this point, there is the 2014 Edition and 2015 Edition. Most notably, the 2015 Edition will be required by federal programs in 2019.  

Who is impacted?

MACRA created QPP and its requirements for all Eligible Clinicians (ECs). ECs are certain types of individual providers who are eligible for QPP and MIPS. Currently, the list of provider types considered to be ECs includes:  

  • Physicians (including doctors of medicine, doctors of osteopathy (including osteopathic practitioners) 
  • Doctors of dental surgery and dental medicine 
  • Doctors of podiatric medicine 
  • Doctors of optometry 
  • Chiropractors 
  • Nurse practitioners 
  • Physician assistants 
  • Certified Registered Nurse Anesthetists (CRNAs)
  • Clinical nurse specialists 

CMS has proposed to expand the definition of EC beginning in 2019 to include physical therapists, occupational therapists, speech language pathologists, qualified audiologists, certified nurse mid-wives, clinical social workers, clinical psychologists, registered dieticians and nutrition professionals.

Assuming CMS’s proposal to expand the definition of EC is adopted, all these provider types would need to review their compliance with QPP. This proposal will be finalized in the 2019 Physician Fee Schedule (PFS) final rule in early November.  

Why is the CEHRT requirement expanding?

QPP is divided into two programs: 1) MIPS, which is also divided into four separate performance categories; and 2) Advanced APMs (A-APMs). Both programs have CEHRT requirements. The A-APM side of QPP has CEHRT requirements that must be met by a percentage of all the EC participants in a given APM at the beginning of the program year, and for each program year. Most program years begin on January 1. These requirements must be met as part of the base definition of what QPP defines as a Medicare A-APM.    

Beginning in 2019, QPP will also include Other Payer A-APMs, which must meet the same definition as a Medicare A-APM but are created by non-Medicare payers. In 2019, these Other Payer A-APMs can include Medicaid APMs and Medicare Advantage (MA) APMs. In 2020, commercial payer APMs can meet the definition of Other Payer A-APMs.  

EC participants in A-APMs, Other Payer A-APMs and APMs that require CEHRT must fulfill CEHRT requirements. As these programs expand into non-Medicare payers, the scope of programs requiring CEHRT will continue to grow. 

What CEHRT is needed? 

After looking at who needs to have and use CEHRT and why that list is expanding, we must turn to what exactly is needed to meet the requirements.  

At a high level, 2015 Edition CEHRT is a health IT product that meets the testing requirements for ONC’s Base EHR, which requires the ability to capture basic clinical health information (including demographics, sexual orientation and gender identity (SO/GO) and implantable devices) and perform basic EHR functions (i.e. Clinical Decision Support (CDS)). It also requires the ability to exchange certain information with other CEHRT in a standard format (i.e. transition of care – sending and receiving; data export) as well as support reporting electronic Clinical Quality Measures (eCQMs), the patient portal and application programming interface (API) functionalities. The Base EHR definition also includes the ability to capture clinical information included in the Common Clinical Data Set (CCDS), which is required by three certification criteria in the Base EHR definition.  

Next, 2015 Edition CEHRT (pushed to becoming mandatory in 2019 instead of 2018) must meet a few additional criteria such as family health history; patient health information capture; eCQM functionality related to importing clinical data, calculating and reporting quality measures; and functional reporting. The definition of 2015 Edition CEHRT for QPP and Medicare/Medicaid PI also includes a requirement for CEHRT necessary to be a Meaningful EHR User or as required by MIPS PI. This means that certification criteria related to required measures for the PI category of MIPS and the Medicare and Medicaid PI programs – such as e-prescribing and Computerized Provider Order Entry (CPOE) – are included in the definition of CEHRT.  

CMS has defined CEHRT for QPP to align the definition of all other programs requiring CEHRT to ensure there is a single common CEHRT definition. This means that regardless of how or why a provider is participating in a program, the requirements for the possession and use of CEHRT are the same. Therefore, if a provider is participating in an APM requiring CEHRT, that provider needs to ensure compliance with CEHRT requirements as noted above or the APM may be out of compliance.  

Keep in mind, moving into 2019, the list of EC types grows, the list of APMs requiring CEHRT for QPP grows, and the requirements for CEHRT move to the 2015 edition. Moving into 2020, we may see additional growth in the CEHRT requirements. This is an area to keep an eye on and ensure compliance for your organization.  

How will you stay ahead of the curve with new regulatory requirements? Count on Cerner to lead you through the future of regulatory compliance. Learn more here.