On March 9th, 2020, the Office of the National Coordinator (ONC) for Healthcare IT announced the latest Final Rule for the HIT Certification Program known as the 21st Century Cures Act or the 2015 Cures Act Update. This update requires that eligible clinicians must abide by CEHRT requirements for the Promoting Interoperability (PI) performance category starting in Performance Year (PY) 2023. Here’s everything you need to know.
CEHRT / Base EHR Gap
Due to some confusion on the terms, the CEHRT/Base EHR Gap identifies the differences between the CEHRT and the Base EHR.
The 2015 Base EHR is defined by ONC as a record of health-related information on an individual that includes demographic and clinical health information with certain capacities to support the entry and organization of data.
Certified Electronic Health Record Technology, or CEHRT, is a regulatory term defined by CMS that encompasses all information included in the Base EHR, as well as extra information such as family health history, patient health information capture, and more.
This diagram from Healthcare Inoperability & Quality Services highlights the CEHRT/Base EHR Gap:
Changes Made in the 2015 Cures Act Update
The Final Rule made several changes to the original 2015 Cures Act. Here are a few of them from the Center for Medicare and Medicaid Services website:
- New technical certification criteria to advance interoperability and make it easier for patients to access their own electronic health information on their smartphones.
- New privacy and security certification criteria.
- Revised the standards referenced by several existing 2015 Edition certification criteria, including United States Core Data for Interoperability updates.
- Removed and time-limited several 2015 Edition certification criteria.
How This Will Affect MIPS
In relation to MIPS, these changes will directly impact the Promoting Interoperability (PI) category of your MIPS submissions. The 2023 CEHRT requirements for the Promoting Interoperability performance category are as follows:
- 2015 Edition Cures Update functionality must be used as needed for a measure action to count in the numerator during the performance period chosen by the eligible clinician or group (a minimum of any continuous 90 days in 2023).
- In some situations, the product may be deployed during the performance period but pending certification. In such cases, the product must be updated to the 2015 Edition Cures Update criteria by the last day of the performance period.
- MIPS eligible clinicians must provide their EHR’s CMS Identification code from the Certified Health IT Product List (CHPL), available on HealthIT.gov, when submitting their data.
In order to make your transition as smooth as possible, we encourage you to talk to your EHR vendor about updating to the 2015 Edition CURES Update version of the CEHRT as soon as they are able.
The QPP Website shares more information on the PI Category in MIPS.
Other important links: