A recent change in the rules governing physicians’ use of electronic health records (EHRs) spares doctors from having to upgrade their systems by the end of this year.
Even with this rule change, however, physicians still face great uncertainty with regard to their EHRs and how they must report quality data to the Centers for Medicare & Medicaid Services (CMS).
Under the Merit-based Incentive Payment System (MIPS), Medicare’s new pay-for-performance program, doctors could lose money unless they score higher than average in MIPS’s three performance categories: quality, practice improvement and the use of EHRs—the category known as Advancing Care Information.
Until recently, they also had to upgrade their EHRs to the latest government-certified versions to meet all MIPS requirements in 2018. Participants in qualified Alternative Payment Models—the other track in CMS’s program—also had to get upgrades.
But in late June, CMS proposed that physicians be allowed to use either their current “2014 edition” certified EHRs or the new “2015 edition” certified products in 2018. Although the final rule won’t be issued until fall, observers expect this feature to be included in it.
While this move by CMS gives physicians some breathing space, it also raises a number of questions. For starters, when will practices have access to the new EHRs? Should physicians accept a 2015 edition upgrade when their vendor makes it available?
How will the Medicare payment program’s proposed rule affect Advancing Care Information requirements, depending on whether a practice has a 2014 edition or a 2015 edition product? Will the upgraded versions give them what they need to report quality data directly to CMS?
Physicians will not need 2015 edition EHRs to do quality reporting or to report their practice improvement activities under MIPS next year. But they will have to report on quality measures for a full calendar year, which means they need to gear up their reporting strategy before January 1, 2018.