What Providers Need to Know About EHR Mandates in 2018

Incentives for meaningful use of electronic health records (EHRs) accomplished the goal of increasing the use of electronic documentation of patient records, yet the requirements continue. The Centers for Medicare & Medicaid Services (CMS) issued a final rule last summer.

So what do physicians and other healthcare professionals need to know about the CMS EHR mandates in 2018?

“The final rule, published August 14, 2017, puts additional emphasis on data sharing and interoperability, while relaxing specific components, including the shorter reporting period,” said Chad Anguilm, director of in-practice technology services for Medical Advantage Group, a wholly owned subsidiary of The Doctors Company, based in Napa, California.

The incentive program ended with the 2016 reporting period. However, that does not mean everyone can go back to using paper. Clinicians must report to the CMS Quality Payment Program.

To potentially earn a positive payment adjustment under the Merit-based Incentive Payment System (MIPS) track of the Quality Payment Program, physicians and advanced practitioners must submit data about the care they provided and how their practice used technology in 2017 by March 31, 2018.

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Relaxing the original EHR requirements

Initially CMS said providers should be using an EHR for the full calendar year. Those newly attesting had to report any continuous 90 days.

“The revised reporting period is a continuous 90 days between January 1, 2018, and December 31, 2018, instead of a full year,” Anguilm explained.

The initial plan called for eligible professionals using technology certified to the 2015 edition CEHRT (Certified EHR Technology). However, the Office of the National Coordinator for Health IT (ONC) Certification Program had decertified 74 products as of January 9, 2018.

CMS policy now will allow eligible professionals to use a certified 2014 edition, a 2015 edition or a combination of both for reporting in 2018, Anguilm said.

“This policy is based on the ongoing monitoring of advancement on the deployment of EHR technology certified to the 2015 Edition, as well as feedback by stakeholders expressing the need for more time and resources for the transition process,” Anguilm said.

Many of the major EHR vendors are still seeking 2015 certification.

Liz Johnson, board chair of the College of Healthcare Information Management Executives and CIO of Acute Care Hospitals & Applied Clinical Informatics at Tenet Healthcare Corp., said in a statement. “By no longer requiring these new systems be in place by the start of 2018, a huge weight has been lifted off our collective shoulders.”

“In accordance with the 21st Century Cures Act, those providers unable to satisfy meaningful use requirements because their certified electronic health record (EHR) technology is now decertified or will be decertified can avoid meaningful use penalties,” Anguilm added.

Anguilm recommended “that eligible providers currently using an EHR that has been decertified or planning to decertify begin looking for a new platform with 2015 certification immediately. Although an eligible provider will not be penalized for using a decertified EHR in 2017, there also will not be any incentive payouts to their benefit.”

Eligible providers who spend most of their time in ambulatory surgical centers struggled to meet the objectives given their involvement with the patient being much different than the typical patient–provider relationship, Anguilm explained. “In 2018, most of these providers will avoid Medicare payment adjustments.”

The new timeline for Stage 3 meaningful use

Among the fallen EHR mandates in 2018 is compliance with State 3 meaningful use, which focused on using certified electronic health records to improve health outcomes.

All providers were supposed to participate in Stage 3, which involves coordination of care through patient engagement, health information exchange and public health reporting. CMS thought having everyone at Stage 3 would simplify reporting requirements.

However, in the final rule, allowing providers to use the 2014 edition of CEHRT, participants in the meaningful use program will be able to still attest to Stage 2 objectives and delay Stage 3 until 2019.

But the next stage is coming, and an unofficial EHR mandate in 2018 should be to prepare, not delay projects of Stage 3, so eligible providers are ready.

Anguilm expected “the combination of a 90-day Meaningful Use reporting period along with giving eligible providers until 2019 before they have to switch to 2015 CEHRT will likely make most eligible providers and the EHR vendors happy, for now.”

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