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When are MIPS Eligible Clinicians Required to be Using 2015 Edition Certified EHRs?

11/28/2018

The answer to when 2015 Edition Certified Electronic Health Records (EHRs) are required is a complex answer. We will refer to "2015 Edition" and "2015 CEHRT or certified" to help clarify. Although it is recommended that everyone upgrade to 2015 Edition as soon as possible, the upgrade does not have to be complete/certified by January 1, 2019.
The Centers for Medicare & Medicaid Services (CMS) has made the following distinctions to help you understand the process. The date of having 2015 Edition means that you have all of the 2015 functionality available to you. The date of having "certified" 2015 Edition means that your EHR vendor has received formal certification by an ONC-Authorized Certification Body (ONC-ACB) to meet criteria adopted by the Secretary of the Department of Health and Human Services (HHS). There may be instances when an EHR vendor provides 2015 Edition to a practice, but the EHR is not certified yet by an ONC-ACB. Below are explanations of when 2015 Edition is required for the Promoting Interoperability and Quality categories and when that 2015 Edition must be certified.  
 
PROMOTING INTEROPERABILITY (PI) CATEGORY (2019: Will need 90 continuous days for reporting)
To earn points in the PI category, you need to use a 2015 Edition EHR for the entire duration of the performance period.  Since this category requires a minimum reporting period of 90 continuous days, the 2015 Edition must be in place by day one of the reporting period so the practice has access to all of the functionality and features that are in the 2015 Edition. It is recommended that the 2015 Edition is also certified by day one of the reporting period, but it is acceptable if the vendor did not receive certification of their 2015 Edition prior to upgrading the practice's EHR. The requirement is that the vendor must receive certification by an ONC-ACB prior to the last day of the reporting period.
 
Examples: 
  • 90-day reporting period is May 1 through July 31. The practice must have 2015 Edition in place on May 1 and EHR must be certified by July 31.
  • 90-day reporting period is October 2 through December 31. The practice must have 2015 Edition in place on October 2 and EHR must be certified by December 31.
QUALITY CATEGORY (2019: need a full year for reporting)
The timing of when 2015 Edition is needed for the Quality category varies based on how each quality measure is submitted. In 2019, quality measures can be submitted using multiple submission methods.
  • EHR: 2015 Edition EHR is necessary if you are going to submit EHR measures, commonly referred to as eCQMs. Since the quality category performance period is the full calendar year, you need to have 2015 Edition in place by January 1, 2019 and the vendor must receive certification by an ONC-ACB prior to the last day of the reporting period, which is December 31, 2019.
  • Claims: 2015 Edition EHR is not applicable if you are going to submit Medicare Part B claims measures.  In 2019 claims measures can only be submitted by clinicians in a small practice (15 or fewer eligible clinicians), whether participating individually or as a group.
  • Qualified Registry: 2015 Edition EHR is not applicable if you are going to submit MIPS-CQMs (previously called registry measures). Earning the end-to-end electronic reporting bonus is based on the registry's method of data collection and is not based on 2015 Edition EHR certification in any way.
MIPS TIP: For your 2019 MIPS Binder, you may want to include the email from your vendor noting when the upgrade occurred or the invoice for when the 2015 edition was provided as proof of the date. You may also want to save documentation of the date when the EHR received certification of it's 2015 Edition.