It’s 2019 But I Need the 2015 Certified Electronic Health Record?

Since clinicians were first offered a financial incentive to purchase and use an electronic health record (EHR) to obtain bonus money (or avoid penalties), they have been required to use only “certified EHR technology” (CEHRT).  The names of the various payment programs have changed over time, starting with “Meaningful Use” and now the Merit Based Incentive Payment System (MIPS). Clinicians have been held to increasingly more difficult standards in the way they use their EHRs, and the EHR vendors have been held to increasingly more demanding certification standards to support these activities. The CEHRT standard which takes effect in 2019 was intended to be required in 2015, but there were delays along the way. As a result, in 2019 the new standard is the “2015 Edition CEHRT.”

It’s frustrating enough adjusting to the newest smartphone (where is the “Home” button?). It often feels like things are changed for no good reason. However, there is a “reason” for the drive to the 2015 CEHRT standard, even if it is not apparent. A major goal is for every EHR system, regardless of whether it is a major hospital or a solo practitioner, to be able to exchange a standard set of patient healthcare data. This two-way communication is called “interoperability.”  A product that is not 2015 Edition certified might not be able to exchange patient data with a system that’s still at the 2014 CEHRT level (or earlier). Other goals for the 2015 Edition CEHRT are to ensure privacy and security, as well as to improve patient safety. 2015 Edition CEHRT products allow incorporation of patient-generated health data and the recording of implanted medical devices (which include cellular- and/or tissue-based products).

If you are not sure which EHR certification version is installed in your practice, you can find out on the Certified Health IT product list.

The ONC has a checklist of things to consider when upgrading to the “2015 CEHRT” standard. Here’s a partial list:

  • Check your existing computer systems for compatibility
    • Will you have to upgrade your equipment?
  • Make sure you have the required internet bandwidth
  • Evaluate what has changed from the old version (your EHR vendor is probably beginning this education process with you now).
    • How will it affect workflow?
    • What tasks will be easier?
    • Will any tasks be harder?
    • Does it comply with all the 2015 CEHRT requirements?
  • Is there a cost associated with the upgrade?
  • How long will the upgrade take?
    • Will it require downtime during office hours?
  • What training will the vendor provide?
    • Is there a cost for training?
    • Schedule staff training in advance
  • What support does the vendor provide during the upgrade process?
  • Will you need to lighten your schedule for awhile after you first go live?
  • Pick a go-live date

A big reason to make sure your EHR is on the 2015 CEHRT list is that it’s required for participation in Medicaid Meaningful Use and the Promoting Interoperability (PI) category of MIPS. Promoting Interoperability (formerly Meaningful Use and then Advancing Care Information) is one of four MIPS performance categories that affect a clinician’s Medicare Part B payments, along with quality, cost, and Improvement Activities (IAs). Physicians using their EHR to report all performance categories need the 2015 CEHRT for the full year because the quality category requires full calendar-year reporting. The PI and IA categories require a continuous 90-day reporting period. That means physicians could upgrade as late as October 1, 2019.  I wouldn’t wait until that late.


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